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The Post Office Horizon IT Inquiry
Friday, 14 June 2024
(9.45 am)
ANDREW PAUL PARSONS (continued)
Questioned by MR BLAKE (continued)
MR BLAKE: Good morning, sir, can you see and hear me?
SIR WYN WILLIAMS: Yes, I can, thank you.
MR BLAKE: Thank you very much.
Mr Parsons, today I'm only going to be about an hour
long and I just have a few miscellaneous topics to
cover.
Before I do that could we please bring up on to
screen WITN10390201. Yesterday when we confirmed the
truth of your witness statement, there were also some
amendments to be made, largely to spellings and
reference numbers. Can you confirm that, subject to
what we see on screen now, the statement that you
confirmed as true is true to the best of your knowledge
and belief?
A. That is correct.
Q. Thank you very much, that can come down.
I'm going to begin today by asking a few more
questions about the litigation. We left off yesterday
with that strategy document. I want to ask you first
about issues with witnesses. Could we please turn to
FUJ00182166, please. If we could look at the bottom
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"I had a conversation this morning with Andrew
Parsons, the partner at [Womble Bond Dickinson] handling
the case, and he made it very clear that it was
absolutely essential for the Post Office case that Steve
Parker appear as witness to rebut Mr Roll's [witness
statement]. [Womble Bond Dickinson] did make clear that
Steve would receive witness training and support.
"He also said it was extremely urgent that we
convince Steve to be a witness and asked if I could
respond today on this.”
Do you recall an issue with this particular witness
being concerned about giving evidence.
A. Yes.
Q. There's reference there to witness training. Did he
receive witness training?
A. I can't recall if he specifically did but we offered
witness training through a third-party company to,
I think, all of our witnesses.
Q. How about support?
A. I can't recall specifically what support was given to
Steve Parker.
Q. If we look at the email that was attached to that email,
can we please look at FUJ00182096. I don't know if you
will have seen this at the time but I just want to ask
you about the concerns that he expressed in that email:
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email, it's an email of 22 October 2018, from somebody
called Chris Jay to David Jones. He says as follows:
"The claimants and Post Office are at the stage of
exchanging witness statements.
"One of the claimants’ witnesses is a Richard Rolls
[sic]. He used to work for Fujitsu and left in about
2004. His witness statement is attached.
"We have checked to see if he left under a shadow
and have no evidence that he did. He did however appear
on the Panorama programme a few years ago about the Post
Office and Horizon, which I did not see, but which from
Womble Bond Dickinson believe that the claimants and
their lawyers Freeths, determined that he may be able to
assist with their case.
"One of our team, Steve Parker, worked with Mr Rolls
[sic] and gave him a positive reference. Steve is now
involved assisting Post Office the defence and has
commented on Mr Roll's [witness statements] (see
attached). He has made clear that he does not wish to
give a [witness statement] and appear in court as he saw
the effect on another colleague. See attached
correspondence with Jonny Gribble [sic] of [Womble Bond
Dickinson] on the latter point.
"I also attach Gareth Jenkins' commentary on Richard
Roll’s [witness statement] for information.
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"The minutes of our meeting are being turned into
a witness statement. I have seen this process
previously where a colleague signed such a statement
which resulted in a very stressful court appearance.
1am happy to continue supporting the process and
refining the information but I will not be signing
a witness statement, we need to find another way to use
this information.
"Steve."
Can you recall any discussions on this topic with
Mr Parker?
I can't recall any discussions directly with Mr Parker.
Did you understand anything about that court appearance
that he is referring to in that email?
I don't believe I did.
Could we please turn to FUJ00160244. Just on that, you
said you don't believe you did; do you now? Is there
anything you know about that now?
No, there's nothing I know now about that.
This is on the same topic, if we start on page 4,
please, about halfway down, thank you. It's an email
from Graham Allen to Chris, Chris Jay. He says:
"Chris
"Steve and I are both early starters so I have had
a long conversation with Steve this morning.
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“lam afraid he is adamant that he does not want to
voluntarily put himself through the stress he feels this
will generate despite wanting to defend the team from
that time. He was expecting someone to come back to him
and had already given it a great deal of thought. He is
aware that he may get subpoenaed and would deal with
that if it happened. He didn't think sharing the load
with another team member would help.
"I tried to persuade but did not want to push too
hard; not sure what else we can try. Steve is not the
sort of person to take decisions lightly or be easily
swayed from his chosen direction."
If we scroll over to the first page, we can see that
there is a response from you, at the bottom of the page.
You say:
"There isn't an alternative to witness evidence. We
could look at summonsing Steve but that would be far
from ideal.
"We need to urgently (today?) work out whether there
is an alternative to Steve. If that hits a dead end
then we will need to regroup and think again."
If we scroll up to the top there's a response, at
the very top of the page, please:
"Andy,
"Have just heard back from the Account team
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Can we please turn to the third page. It sets out
various litigation strategy options as they then stood,
and I'd like you to look at number 5, "Attrition". It
says there:
"Stretch out the litigation process so to increase
costs in the hope that the Claimants, and more
particularly their litigation funder, decide that it is
too costly to pursue the litigation and give up."
It says:
"Recommendation: this option is not recommended as
we believe the pressure on, and cost to, Post Office
would become unbearable before the claimants gave up."
We see that on the right-hand side the reasons for
that:
"The claimants’ litigation funder ... is
an experienced funder with deep pockets. It will be
prepared for a long piece of litigation. So long as it
believes the merits of the case are favourable, it can
be expected to fund the litigation.
"Over time the litigation will become more
disruptive to Post Office's business as more operating
practices are put under the spotlight and then have to
be overseen by lawyers in order to avoid problems in the
litigation process.
"Although media reporting on this matter is
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[regarding] John Simpkins. Unfortunately he does not
wish to become a witness either. Suggest we rethink."
What did you understand the concerns of these
individuals at Fujitsu to be about being called as
witnesses in the Group Litigation?
I don't believe I knew anything about John Simpkins’
concerns. The understanding I had of Steve Parker is he
just had a natural reluctance to be a witness and, from
those emails, it appears it was because he had had
a friend or someone he knew had given evidence somewhere
else but I didn't know much more than that.
Were you aware of, for example, any historic issues
within Fujitsu which would mean that individuals were
reluctant to give evidence? We've heard, for example,
in this Inquiry, about Anne Chambers giving evidence and
being unhappy about the situation that she was put in.
Nobody drew my attention to any connection between
Steve's concems and any matters like that.
I want to move on now to the strategy towards the
claimants themselves. Can we please turn to
POL00006379. This a document entitled "Litigation
Strategy Options" produced for the steering group
meeting of 11 September 2017. Was this a document that
you produced?
It was either me or my team.
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presently low key, there is increasing chatter in the
network and a feeling that the litigation may start to
dissuade individuals from being postmasters. This will
increase as the litigation continues without a result in
Post Office's favour."
So, at that stage, the clear recommendation is not
to go for attrition because there are, amongst other
things, downsides for the business and also the costs to
the Post Office in pursuing that would be very
significant; is that a fair summary?
Correct. I would also just note there bullet 2 in
column 2, which explains that what this means in
practice would be agreeing with the claimants’ proposals
for case management and they, at that time, were
advocating a long course for the litigation.
Thank you. You've addressed this in your witness
statement. Can we bring up your witness statement,
please. It's page 204. Thank you.
Page 204, I think you've set it out at paragraphs
357 to 359. I just want to have a look at 357 and 358
if we may. You say there:
"As for option 5 [that's option 5 from the document,
the "Attrition" option] as the paper makes clear, this
was not a strategy I recommended because the cost to
[the Post Office] would be too high before the claimants
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would feel the impact of this approach. Insofar as it
is to be suggested that this approach -- or indeed any
approach which had the effect of applying pressure to
the claimants -- would have been inappropriate (or that
any individual steps that [Post Office] took that put
pressure on the claimants were inappropriate),
I highlight that applying a reasonable degree of
pressure to one's opponent, and/or pursuing strategies
which have the effect of applying pressure to one's
opponent, are part and parcel of an adversarial system
oflitigation. It was proper to include this so [the
Post Office] could see the full range of options.
However, at no stage did I recommend that [the Post
Office] adopt this strategy and at no stage did [the
Post Office] instruct me to adopt such a strategy."
Just pausing there, you say that it's part and
parcel of an adversarial system of litigation. For you,
does it make any difference whether the party is owned
by the Government or not?
I saw this as an ordinary piece of commercial
litigation.
Then 358:
"More generally, as explained above, where it was
consistent with my duties to the Court, my client and my
professional obligations for [Womble Bond Dickinson] to
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"On 19 October 2017 there will be a Case Management
Conference. At this court hearing, a judge will decide
on the strategy strategic direction of the Group
Litigation ...
"This paper explains:
"The nature of a CMC and the court process that may
flow from it.
"The general strategic direction that we recommend
is adopted by the Post Office."
Is this a document that you produced?
I suspect I was the primary author but it may have had
input from others as well.
If we scroll over the page, please, there's a section on
overall Post Office strategy and it’s very similar to
the strategy that we saw in that email from you
yesterday. I'll just read a few sections from it:
"There are no silver bullets in this case that will
dispose of all claims in one go ...
"4.2 This leads us to the view that, in the fullness
of time, Post Office may need to address each of the 522
claims individually given the diversity of their
circumstances. Taking [each] case to a full conclusion
through the litigation process is unattractive as it
would take years and the costs would be extremely high.”
So again, similar: it would cost a lot of money for
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advise on approaches which had the effect of applying
pressure on Freeths and the Claimants’ litigation
funder, these approaches would be explained to [the Post
Office] as advantages of a particular step or action.
However, at no stage did I advocate taking a step purely
for this effect. Where this factor infrequently arose,
there was always an overarching meritorious reason for
recommending a particular course of action, a byproduct
of which may have been to place pressure on the opposing
Legal Team."
So you're setting out there that, at no point, did
you recommend that as a strategy, it may be a byproduct
of some other strategy; is that a fair summary of that?
What we're talking about here is what I would call is
a pure attrition strategy, where a party takes
unreasonable points for the predominant purpose of
causing one's opponent to incur costs. I don't believe
I ever advised Post Office to take such a strategy.
There were times during the litigation where there were
meritorious reasons to take a point that had a byproduct
of applying pressure onto the claimants.
Thank you. Could we please turn to POL00006380.
I think this is another document you've explained in
your witness statement. We're now on 11 September 2017.
It says:
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the Post Office to pursue that kind of a strategy,
therefore not recommended?
Not to take the entire case to conclusion because what
I was anticipating is there would probably be a series
of thematic trials, followed by eventually having to
deal with the details of 500 plus individual claims, and
I didn't think that was practically feasible.
“4.3 We believe the better solution is to try to force
the claimants into a collective position where they will
either abandon the claims or seek a reasonable
settlement. It should be remembered that the claims are
financially supported by Freeths (whose fees are at
least partially conditional on winning), a third party
funder and insurers. Without this support these
proceedings would not have been possible. All three
entities will likely have the power to pull their
support if the merits of the case drop below a certain
level. Our target audience is therefore Freeths, the
funder and the insurers who will adopt a cold, logical
assessment of whether they will get a payout, rather
than the Claimants who may wish to fight on principle
regardless of merit.”
So that isn't advocating, at this point, a strategy
of attrition but it is saying that we need to keep
an eye on those who are actually funding the litigation?
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A. Yes, and the key point of that sentence is that it
refers to the fact that those entities may pull their
support if the merits of the case drop below a certain
level. So this is advocating a merit-based strategy.
Does something change over time or is it your position
that that was the approach throughout?
I think that was largely the approach throughout. Later
in the litigation, I think this is probably around the
time of the trials, I got an impression, but I had no
information, that the claimants' Legal Team were
struggling, potentially, to keep up with the pace. We
were also struggling, to be fair. And we did in
that became a bigger issue to consider, to factor in but
I think always we were advocating strategies that had
merit.
Could we please turn to POL00111290. So this is a year
later now, if we scroll down, 1 November 2018 and, as
you say, I think this is probably the document, you may
have been thinking about it, thinking about a third
trial. So it says:
“All
"This is a long email setting out some initial
thoughts on a possible trial in May 2019. I presume
that at some point during the [Common Issues] trial
Fraser will grab one of the free days to talk about this
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and
I'd like to take you to the fifth one of those, it
begins "We should":
"We should not assume that we have deeper resources
than the [claimants]. We undoubtedly have more bench
strength but every task is much more onerous for us (our
disclosure is at least 10 times larger than the
[claimants']; we will have loads of witnesses, they will
have a few, etc).”
Then you say:
"That said, my instinct is the [claimants'] funding
is under pressure and they do not want to be burning
money on a 3rd trial.”
Is this is the turning point you were describing
just now?
I wouldn't describe it as a turning point, it was just
an impression that we began to have, or I began to have
around that time.
If we please turn to page 5 there is the straw man that
you are setting up for others to comment on. You say as
follows:
"Drawing the attached together, I think we need
a plan that can be [flexed] to accommodate the
possibility of an appeal. Also tactically the best
option for [the Post Office] are (i) to force the
[claimants] to burn money and (ii) to target limitation.
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and so we need a plan. The below represents a straw man
for everyone to take shots at.
"I appreciate that everyone is extremely busy but we
need to put some time aside with the full Counsel team
to talk through our proposal for May. I'm going to
suggest a [conference] call for Monday at 10.00. Shout
now if you really can't do it.
Also, I'm sure everyone can raise a million reasons
why the below is crazy ... I think it's crazy ... but we
need to find a way forward so we all need a positive (if
deluded) mental attitude!"
If we scroll over to the next page, please, "Key
dates". So the Common Issues trial finishes on
6 December, Horizon Issues trial begins 12 March onwards.
and you're planning for the future.
"General objectives of a third trial
"I can see 3, potentially conflicting, objectives
for a 3rd trial:
"1. To progress the litigation as a whole towards
conclusion.
"2. To secure some form of tactical advantage that
forces the [claimants] to quit/settle.
"3. To keep Fraser happy by doing something
‘productive’ in May '19.
"Challenges/factors [for consideration] ..."
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My straw man therefore tries to achieve these objectives
whilst trying not to look tactical!"
Then you say, for example:
"We agree to a Lead Cases trial of 3 cases",
et cetera.
Now the witness statement I took you to before said
that you never advised that as a strategy. Here, we
have, it seems, you're advising that at this point in
time a strategy to force the claimants to burn money; do
you agree with that?
I don't agree with that. This is a straw man discussion
amongst the lawyers with the counsel team. I think
I did forward it to Rodric Williams but it's expressly
under cover of an email that says, "This isn't advice"
I think I used the phrase "brain dump of ideas". These
points were discussed, even here though the strategy is
to target limitation and, if you scroll slightly up in
this email, you can see I set out the advantages of
targeting a limitation issue, so there was reasonable
merit.
And, in any event, what happened in practice was
that the trial date moved back and this discussion never
went anywhere. So I don't believe this ever ended up as
actually being advice to the client, as opposed to
a point being discussed amongst the lawyers.
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What is the difference between a “brain dump" to
a client by a solicitor and "advice" from a solicitor?
I think Rodric Williams would have understood this, as
an experienced in-house litigator, that this was just
some ideas that were being knocked around amongst the
Legal Team and it wasn't a settled view on the way that
Post Office should have proceeded.
But it was your view as to how they could proceed?
It was one option. I think if you scroll through the
entire email, it sets out a whole range of different
options and, as it sets out at the start, it's a starter
for ten for discussion amongst the Legal Team.
Could we turn, please, to the judgment in the Common
Issues trial. That's at UKGI00009458, and it's
page 172. About halfway down that paragraph that's on
the top of the page, so if we scroll up slightly,
Mr Justice Fraser says as follows:
"The Post Office has appeared determined to make
this litigation, and therefore resolution of this
intractable dispute, as difficult and expensive as it
can."
Does that not reflect the advice that you were
giving to Post Office in 2018?
As I say, I don't accept that that was the advice that
was given to Post Office. It was an idea being
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Let's turn to that, then. Can we please turn to
WBON0000528, please. This is in 2018, so two years
after that apparent meeting. Now, this is an email from
Amy Prime to you, "Subject: Notes from call with [the
Post Office] on 23 March [2018]". Can you assist us, is
this Amy Prime sending you notes that she took while you
were having this discussion?
Give me a moment to read, please.
We can scroll down, if you like. Perhaps I'll take you
through some paragraphs and, at the end, you can tell me
how you think this was formulated?
Thank you.
She says:
"Andy
"Notes from the beginning of the call below:
"BEIS and UKGI are taking a more proactive approach,
two issues with this (1) in relation to piece of
litigation they got stung so worried about no surprise
in [Post Office litigation]; and (2) wish to protect
public money and value for money so being quite
intrusive. Bill of £110 million in compensation to
supplier in nuclear procurement deal which has caused
more intrusive oversight.”
It then refers down there to Tom Cooper. So Tom
Cooper was from UKGI, he sat on the Board of the Post
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discussed amongst the lawyers and, ultimately, it never
came to fruition because the trial date moved back and
matters moved on. I don't think, actually, decisions
around trial 3 were made for several months after that
point.
I'm going to move on to another topic now and that's the
Post Office's relationship with Government and UKGI.
Rodric Williams has given evidence to this Inquiry
describing a meeting in the middle of 2016 with the
Department for Business -- I think he said that you were
present at that meeting -- where the Department was
asked by the Post Office to be able to conduct the
litigation without external influence. Is that
a meeting you have any recollection of?
I'm afraid I have no recollection of that.
Do you think it's likely you attended a meeting with the
Department for Business in mid-2016?
I don't recall - I don't recall any meetings with the
Department for Business. I recall --
UKGI?
Sorry, or UKGI. I recall briefing one of the Board
directors who had been appointed by UKGI, I think there
were some UKGI attendees at that meeting.
Was that Tom Cooper?
Itwas Tom Cooper.
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Office as well; is that right?
Yeah, he was on the Board of directors at Post Office
and, as I understood it, UKGI had the power to appoint
a director to the Board.
So it says:
question whether we are tying him down to
an information sharing structure and signing
[a non-disclosure agreement]? Not NDA, director of
company so has confidentiality undertakings already.
Appointment letter has made issues with confidentiality.
UKGI want Tom to tell UKGI what he wants to and not be
constrained in his emailed to share information."
So it looks as though there is a concern being
expressed at this meeting about the ability for Tom
Cooper, who sat on the Post Office Board, to share
information with UKGI; is that your recollection of the
discussion?
It's not my recollection because I'm not sure that I was
on this call or not but that appears to be what the
words are saying there.
Do you recall an issue at this point in time arising
from UKGI wanting to know more about the litigation and
perhaps the Post Office pushing back on that information
sharing?
I was aware that there was an issue with information
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sharing with UKGI, particularly around sharing
privileged information with UKGI and how to do it in
a way that would maintain privilege.
Was that a concern that you personally had?
I would always be concerned about issues around
privilege and making sure that Post Office were properly
advised on those issues.
Having read just those couple of paragraphs, are you
able to assist us any further with how this note might
have come about?
I'm afraid not. I don't recall this note and I don't
recall the call that it appears to be referring to.
"After CCRC material, deeply suspicious about ability of
UKGI to control flow of information."
Is that something that you're able to assist us
with?
I'm afraid not.
It looks as though there was a concern that UKGI had
shared some information relating to the Criminal Cases
Review Commission; is that something you recall anything
about?
I don't recall that.
If we scroll down slightly more:
"Will give board update on progress of [litigation]
as per [Womble Bond Dickinson] speaking notes.
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board and UKGI were mainly handled in-house by the Post
Office Legal Team. I recall there was a concern, not
about providing written updates but just the sheer
volume of written updates that were being requested and
the capacity and practicality of providing them.
The suggestion here, though, seems to be, to use the
language we were speaking about yesterday, updating on
a verbal basis, rather than a written basis. As you
say, you've expressed concerns about privilege.
Mm-hm.
Do you recall those kinds of concerns in relation to
UKGI?
I recall that Post Office had concerns about, if they
provided information to UKGI, where else would it then
go after that? Other than that high level, I don't
recall what the detail was or what caused Post Office to
have those concerns.
The final document on that topic, can we please turn to
POL00041770. If we start on page 2, please, the second
half of page 2. I think you've addressed this in your
witness statement at paragraph 433. We don't need to
turn to the witness statement but, if we could just have
a look at this email from Elizabeth O'Neill at UKGI to
Rodric Williams, it's about agreeing a protocol with
UKGI, I think, for information sharing. She says:
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"Discuss protocol for engagement with UKGI and
concerns with appointment of Tom Cooper."
Do you recall at this period a wish for Mr Cooper to
stick to notes that were prepared by Womble Bond
Dickinson to update UKGI, rather than, for example,
being able to speak freely?
I don't recall -- I don't recall that issue being raised
with me.
If we scroll down, please, over the page, to near the
bottom of that page. It says:
“Alex Chisholm is accounting officer for Post Office
and accountable for spend in [Post Office] to
ministers.”
It says at the bottom:
"Subcommittee papers to be kept to a minimum and
updates from Committee to Board to be verbal, Tom Cooper
will be updating UKGI which causes issues with directors
duties."
It might be suggested that that is quite consistent
with some of the advice that we saw from you yesterday,
keeping papers to a minimum, updates to the Board to be
verbal. Is that advice that you gave in relation to
UKGI at this time?
I don't believe I was deeply involved in these
discussions. The arrangements between Post Office's
22
"Thanks for your markup of the protocol. It looks
as though we are still a long way apart on this as your
draft doesn't recognise a number of things that are
essential to us in order to fulfil our function as
shareholder and representative of the [Secretary of
State].
"So I thought it would be helpful to provide some
important background and explain the context in which
are operating:
“Alex Chisholm is the accounting officer for [the
Post Office] and as such is accountable to Parliament
for its actions. In order to properly fulfil this role,
he requires full and comprehensive information on the
progress of this litigation. This will not be possible
if [Post Office] is not willing to provide written
updates. We revised our requirements to provide for
updates following reports to the Board to reduce any
administrative burden as far as possible, but we cannot
agree to a protocol which includes no obligation on
[Post Office] to report progress in writing in the
litigation.”
So UKGI seemed to have the impression, at this
stage, that the Post Office don't want to report in
writing relating to the litigation.
If we scroll up to the email above from Jane
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MacLeod, she says:
"Andy, Rod
"I am very concerned about this, and I'm struggling
to see a way through this. Paula has offered a meeting
with Alex Chisholm to explain the issues, and that may
be the only way [to] get round this", and asks for
thoughts.
If we scroll up to the first page, you're included
in this email chain but I don't think you have any
comments to make on this chain. If we scroll down,
please, we see, at the bottom email, Patrick Bourke,
11 May, it says:
"I have just come off the phone to Richard Callard
when this came up.
"Andy, Rod -- shall we get on a call?"
Do you remember any call in 2018 relating to this
issue?
I think I did have a call but I can't remember the
details of it.
Looking at this and just from your general reflections,
to what extent do you consider the Government and UKGI,
so far as you were aware, were properly sighted on the
progress of the litigation?
That's difficult for me to comment on because I had
limited visibility as to what information was moving
25
Are you able to assist us with how these kinds of
minutes would be agreed?
Because this was with Brian, the minutes would have been
prepared by Gavin Matthews, so I don't know what process
he followed. I don't recall though I think,
specifically on this minute, I remember, I think, this
went to Brian for approval, I think.
Brian Altman?
Brian Altman.
Thank you. If we please could turn over the page to the
bottom of the second page. We can see there in this
draft version the penultimate paragraph, please. It
says:
"In relation to the cut-off date, 1 January 2010 was
close to the Horizon Online rollout. Prior to the
[Horizon Online] rollout there was a cash audit done so
that all [Post Office] branches balanced."
If we turn to page 4, we can see these are
an updated version of the minutes and, if we turn to
page 6, we can see the same paragraph there. It's
slightly changed, so it now says:
"In relation to the cut-off date, 1 January 2010 was
close to the Horizon Online rollout. Prior to the
[Horizon Online] rollout there was a cash audit done so
that all [Post Office] branches balanced. [Brian
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from Post Office to UKGI, that was mainly handled by the
Post Office in-house.
From those who we saw copied in or sending those emails,
did they ever give you any impressions about the desire
to which they wanted to share or not share information
with UKGI?
Yeah, there were concerns expressed by, I think, mainly
Jane MacLeod and Rodric Williams about sharing
privileged information with UKGI. That's not because
they didn't want to give it to UKGI; they just wanted to
make sure it was being provided in a way that maintained
privilege and confidentiality around that information
but, beyond that, that was the only impression I had.
Did you provide advice in that respect?
I provided some advice around how they might mark up the
protocol to cover privilege issues.
Thank you. I'm going to move on to my penultimate
topic, certain advice given by Brian Altman. Could we
start with POL00333855, please. These are notes of
a conference on 9 September 2013. First of all, if we
scroll down slightly so you can see some of the
handwritten markings, are you able to assist us with
whose handwriting that is?
It's not mine but I couldn't tell you whose it was
otherwise.
26
Altman] advised that there was no positive duty to seek
out individuals pre-1 January 2010 but if [the Post
Office] was approached it would need to make
case-specific decisions on disclosure."
So it has that extra sentence added there. If we
could also, please, turn to page 3 of this document, we
can see there, in this first version, there's another
section on Mr Altman's advice:
"[Brian Altman] advised considerable caution in
relation to mediation cases involving previously convict
individuals (Seema Misra has already indicated
an intention to be within the scheme). The concern is
that lawyers acting for those individuals may be using
the scheme to obtain information which they would not
[and somebody has put in the word 'normally'] be
entitled to in order to pursue an appeal."
If we turn to page 6, the updated version, we see
there that the word "normally" has been put into that
paragraph, so there seems to be a process by which
somebody is making handwritten changes and the minutes
are updated.
Could we please have on screen, side by side, the
current document, and also POL00333856. If we start on
the first page on both, please, now on the 856 version,
there is also handwriting. Could we scroll down. If we
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keep on scrolling over the page, we can see some more
handwriting. Are you able to assist us at all with that
handwriting?
No, other than to say it's not mine.
You can see that, if we put that side by side with 855
but we look at page 2 of 855 -- sorry, actually, if we
go down the page on the left-hand side to the bottom of
the page -- thank you very much -- that's the "in
relation to the cut-off date" section. On the
right-hand side, if we look at the bottom of page 2,
please, we can see that that wasn't in the original and
has been added in, and we saw the further, final
version, which had those handwritten notes added.
We can see the same, if you go to page 3, on the
left-hand side, and 3 on the right-hand side. So the
right-hand side had "normally" added and that's now in
place on the left-hand side.
It looks as though quite a lot of care has been
taken over the minutes. Is that your understanding of
the practice of your firm around this time, taking these
kinds of minutes?
I don't recall that I was involved in the preparation of
these minutes, so I couldn't comment as to -- I suspect
they were prepared by Gavin and I can't comment as to
what approach he took.
29
Disclosure and Duty to Retain)."
Then Simon says:
"Think [Post Office] have resolved those issues."
If we move on to the actual notes that we've just
been looking at, can we look at POL00021998, and the
bottom of the first page, the note says:
"[Rodric Williams] then confirmed that the weekly
hub meetings were starting to bed in, picking up any
issues across the business which may relate to Horizon,
[Simon Clarke] said there had been some ‘cultural
issues' at the start which had now been overcome but he
thought it was necessary to put duties on individuals",
et cetera.
There is no mention there of the Simon Clarke Advice
‘on the duty to retain, the shredding advice, as we know
it. Can you assist us with why that might be?
I wasn't author of these minutes, unfortunately I can't.
Do you recall at that meeting that issue being
discussed?
I don't recall the meeting.
You don't recall the meeting at all?
I recall there was a meeting, I don't recall the content
of the meeting.
Final topic: Scotland, Northern Ireland. What was your
understanding of the Post Office's legal advisory
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The section there on Brian Altman advising considerable
caution, is that something that you recall from the
meeting?
I don't recall it specifically from the meeting, but the
general tenor of that advice I recall around that time.
Advice coming from Mr Altman himself?
From Mr Altman and also Cartwright King.
Thank you. Could we please move on to POL00139866.
This is Simon Clarke's own note of that particular
meeting -- martin Smith's note of that meeting, thank
you very much.
If we scroll over the page, please, we can see
a section there, halfway down, it says:
"Simon: We discussed last Friday: main problem is
cultural. People in different departments. Needs to be
a proper coming together.
“Rod: A lot of issues not important -- eg turn
computer off and then on again. And then things which
may affect continuity -- still need a steer.
"Simon: We said we would write a protocol: roles and
responsibilities etc, centrally archived: owners of
issues."
Then it says this:
"QC: Refers to a couple of non-identified
individuals (referring to [Simon Clarke's] Advice on
30
arrangements for the devolved nations?
In all regards, do you mean or --
Yes. Did you have any particular understanding about
their actions in Scotland, Northern Ireland or any
involvement in those?
I -- from a civil side, I believe they operated the same
way as they did in England. On a criminal side,
I understood that there was -- that they couldn't bring
private prosecutions in Scotland. I can't remember what
the position was in Northern Ireland.
Did any cases from Scotland or Northern Ireland fall
within the remit of the things that you were advising
on?
Yes, because there were cases from Scotland and Northern
Ireland within the Group Litigation.
And outside of the Group Litigation?
There may have been some in the Mediation Scheme as well
but I now can't recall.
Did you have any involvement with Scottish firms
instructed by the Post Office at any stage?
I can't recall any but I may have done, but I can't
recall.
How about the Scottish CCRC?
I don't recall any.
MR BLAKE: Okay. Thank you very much.
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Sir, those are all of my questions.
SIR WYN WILLIAMS: Right. Now, is it still the case that we
have three would-be questioners --
MR BLAKE: That's correct, yes.
SIR WYN WILLIAMS: -- and that one is -- well, have they
agreed an order between them? Let me put it in that way
first?
MR BLAKE: I believe they have although I think they would
appreciate our first morning break now, if possible,
before we begin.
SIR WYN WILLIAMS: Yes, well, I've got no problem with that.
Given the timescales that you've mentioned to me for
questioning, we can take 15 minutes, can we not?
MR BLAKE: Absolutely.
SIR WYN WILLIAMS: So we'll resume at 10.45.
MR MOLONEY: Sir, for the benefit of (unclear -- microphone
off) can I indicate that, during the course of the
morning, Mr Blake has dealt with the document that
I intended to focus on with Mr Parsons, so I can now say
that the Inquiry will not be burdened with questions
from me.
SIR WYN WILLIAMS: Well, it's never a burden, Mr Moloney,
but thank you for letting me know.
MR BLAKE: In that case, it will be Mr Stein followed by
Mr Henry -- ah, Mr Jacobs followed by Mr Henry.
33
MR BLAKE: Thank you, sir.
Just to add, Ms Dobbin has a few questions, as well.
SIR WYN WILLIAMS: Oh, well, if we're talking about minutes,
then that's no problem.
MR BLAKE: Thank you very much.
(10.34 am)
(A short break)
(10.50 am)
SIR WYN WILLIAMS: Are we ready? Yes. I can see Mr Jacobs
preparing his microphone.
MR JACOBS: Thank you, sir. Can you hear me, sir?
Questioned by MR JACOBS
SIR WYN WILLIAMS: Yes, I can, thank you very much.
MR JACOBS: Mr Parsons, good morning. I ask questions on
behalf of 156 subpostmasters who are Core Participants
in this Inquiry and are represented by Howe+Co. Some of
our clients attended the Inquiry yesterday and are here
today, and many, many others are watching remotely
through the live feed.
The view that they've expressed, and I think you
were asked a question yesterday on the same point, is
that you became too close to your client. We saw
yesterday, after the Panorama programme in 2015, you
asked a question of your client whether the Post Office
could start attacking the postmasters' credibility,
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SIR WYN WILLIAMS: Mr Jacobs, fine. So that's the order.
Just so that we can plan it properly, Mr Jacobs is of
the order of half an hour, yes?
MR JACOBS: Sir, I hope to be shorter but, yes, about half
an hour, sir.
‘SIR WYN WILLIAMS: That's fine, and Mr Henry an hour?
MR HENRY: Sir, would you --
‘SIR WYN WILLIAMS: _ I think we will -- sorry, Mr Henry.
MR HENRY: I do apologise. I didn't mean to cut across you.
I just wanted to see if it might be possible that
I could take an hour and ten.
SIR WYN WILLIAMS: All right. I don't think there's any
problem with that. It's just ensuring that the
stenographer has an appropriate break as between
Mr Jacobs and you. Can I ask you, Mr Henry, do you want
to do your hour and ten in one go, preferably or would
you be happy to have a break in the middle of it?
MR HENRY: I'd be very happy to have a break in the middle
of it, if that is what you and the shorthand-writer.
would like, sir.
SIR WYN WILLIAMS: = Right. Well, we'll see how we go and
I'll bear all those things in mind.
So we'll have our first break now and, since I've
been talking in the 15 minutes, we'll start at 10.50,
Mr Blake.
34
calling people out as the “liars and criminals that they
are", your words, page 111 of the transcript from
yesterday.
Mr Parsons, you had a client which was behaving
badly but, instead of taking a step back, you joined in
with what they were doing. You joined in and helped
them, essentially, throwing subpostmasters under the
bus.
Now, my question for you is, having been taken to
the documents that Mr Blake took you to yesterday and
today, are you now able to accept that that is what you
did?
A. Back at the time, I accept that some of the language
I used was too strong. I look back on some of the
decisions we made and think now we could have made
different decisions and, as I say in my statement,
I apologise for the mistakes my firm made along the way.
But back -- if we're talking back at the beginning of
the process, at that time, I understood Post Office to
have a fairly arguable case, that Horizon worked and, as
a result of that and being their lawyer, I am required
to advance their case on their behalf.
Q. Mr Parsons, did you conspire with your client to
downplay important matters so as to keep subpostmasters
in the dark about the very issues which have given rise
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to this public scandal?
I never conspired with my client in that regard. We
would consider each matter as it came up. Some issues
we thought were more important than others, some issues
we would emphasise more than others and some issues,
which we considered irrelevant, we would de-emphasise.
Well, on the topic, then, of conspiring to downplay
important matters can we look at POL00129392 and it's
page 2 of 3, if we could scroll down.
Mr Parsons, while we're waiting for that to come up
on our screens, it's an email dated 17 June 2014, which
you sent to Chris Aujard, Jarnail Singh, Angela van den
Bogerd, Belinda Crowe and others. We'll just wait for
it to emerge.
Thank you. If we could go down to page 2., and
further down, please. So it's this email here. So it's
from you and you say:
"I've just spoken with [Cartwright King] about a new
CAQR from Howe+Co that references the Helen Rose Report."
Then you talk about the Rose Report being
retrospectively disclosed in a number of prosecution
cases, drawing into question statements made by Gareth
Jenkins, and a copy of the report has made its way to
Howe+Co.
The paragraph I want to highlight is the paragraph
37
responding to CQRs."
My question for you, Mr Parsons, is: looking at this
document, this clearly shows, doesn't it, that you were
concerned that Howe+Co were on the brink of discovering
that Post Office's expert in Horizon-based prosecutions
had not been credible; that's what you were downplaying
or advising to downplay, isn't it?
I think it's important to understand that the Helen Rose
Report contained two separate pieces of information
within the same document. One is the Gareth Jenkins
issue, which was being addressed by the criminal
lawyers, Cartwright King, and they had made a decision,
some, I guess, nine months before this, to disclose the
Helen Rose Report without telling subpostmasters about
the Gareth Jenkins connection.
The second issue in the Helen Rose Report is about
the reversal of transactions, which was the subject of
spot review number 1. Now, from my perspective of
advising on the scheme, where prosecution issues weren't
being considered, the relevant part of that report was
the auto reversal of transactions in spot review one.
So that's my primary viewpoint on it. However, reading
this again now, it seems to me that there was a more --
there was a greater underlying problem here, which was
the original disclosures by the criminal lawyers, and
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that begins "The point of concern", the third paragraph.
"The point of concern is that the MO60 CQR is
starting to make the link between (1) the fact that the
[Helen Rose] Report makes it clear that [Gareth Jenkins]
knew of issues with Horizon and (2) the fact that
[Gareth Jenkins] never mentioned these issues in his
prosecution evidence (see paragraph 53 ...).”
We don't have the CQR to hand.
Then you say:
"This line of inquiry draws into question the
credibility of [Gareth Jenkins'] evidence.”
Then you make a criticism or potential criticism of
Howe+Co, and you say:
"The sharing of the [Helen Rose] Report between
applicants is potentially a breach of solicitors
ethics/contempt of court. However, [Cartwright King]
and I don't believe attacking the solicitors on this
point would be of benefit -- if anything it may draw
more attention to the [Helen Rose] Report."
Then scrolling down again, the advice you give to
your client is:
"Instead, our preferred approach is to downplay the
importance of the [Helen Rose] report in any [Post
Office] investigation reports. We recommend minimising
or ignoring entirely the [Helen Rose] Report when
38
not drawing out that Gareth Jenkins connection.
But it's you, isn't it, giving the advice to downplay
the importance of the Helen Rose Report, not Cartwright
King. You're advising Post Office to minimise and
ignore and downplay the report because you were
concerned that Howe+Co were joining the dots together
and would find out about Gareth Jenkins. This is what
the email says, isn't it?
That was one of the concerns but I would just note, if
you just scroll up slightly in that email, I believe it
says, "I've just spoken to Cartwright King".
Yeah, yeah?
And when it says “our approach", that is clearly
referencing the joint approach of both the criminal
lawyers and the civil lawyers.
The Helen Rose Report was a Pandora's box, effectively,
for solicitors acting for subpostmasters because it
would enable them to challenge the Post Office and say
‘on the reversals and the remote access points, "Well,
you need to prove that the figures that you are accusing
us of inputting actually came from the subpostmaster and
not from the system or from Fujitsu". That would have
been an enormously important thing for Howe+Co and other
lawyers representing people to have known about; that's
right, isn't it?
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Sorry, as I understood it, Howe+Co had the Helen Rose
Report. The only information that had been redacted
from it was personal data. Those redactions were
applied by the criminal lawyers, so I believe the rest
of the issues in the report were there to be read.
But not Gareth Jenkins?
No, correct. Gareth Jenkins’ names had been redacted by
the criminal lawyers.
Well, you confirmed yesterday, didn't you, in questions
put to you by Mr Blake, that you advised that Gareth
Jenkins' name should stay redacted?
As I said yesterday, I was passing on the advice of the
criminal lawyers.
Let's have a look, shall we, going further up the email
chain. So we need to scroll back up again, please.
This was Jarnail Singh's response to the email I have
read out, and he says:
"Andy
"lam happy with the proposed approach and it's
sensible in the circumstances ..."
Then he talks about issues being dealt with on
a case-by-case basis.
My question for you is: what circumstances was
Jarnail Singh talking about? Don't you think he was
referring to evidence having come to light which would
41
about the original decision back in, I guess, mid-2013
following the Clarke Advice and the disclosure of the
Helen Rose Report by the criminal lawyers, as to why
they redacted Gareth Jenkins’ name and why they didn't
call out at that point the connection. At this stage,
I'm looking to pass on the advice from the criminal
lawyers -- which is their decision, they've made those
choices, I'm not a criminal lawyer -- and I'm looking at
it also from the perspective of the scheme. As I say,
from a scheme perspective, it's a different question.
I don't want to repeat myself, Mr Parsons, but this is
you advising your client. This isn’t a Cartwright King
letter, it's your letter, isn't it?
It is but I think it's clear from the email sent below
that I'd spoken to Cartwright King, it reflected
a combined approach, and they're all copied on the
email.
We're now in 2024. It's right, isn't it, Mr Parsons
that if you hadn't advised Post Office to downplay,
minimise or ignore the Gareth Jenkins issue in June
2014, the last ten years of the lives of hundreds of
subpostmasters, who have been convicted, bankrupted,
lost their reputations, would have been very different.
Do you see that?
I do see that but, as I say, I think that goes back to
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cast doubt on Post Office's assertion that Horizon was
robust? Those were the circumstances: he knew and Post
Office knew that their robust mantra could no longer be
maintained.
I don't know what circumstances Jarnail Singh was
referring to there.
Well, isn't the inference that when he says, "I am happy
to take your advice and it's sensible in the
circumstances", that you would know or there would be
an understanding between you as to what the
circumstances were?
I'm reading that now and I can't tell you what Jarnail
Singh had in mind at that point.
You had read the Simon Clarke Advice, I think, about
nearly a year earlier.
Mm-hm.
Do you think he was referring to that because you were
referring to Gareth Jenkins’ credibility in the email?
He could quite possibly, especially given that he was
a criminal lawyer at Post Office.
So, essentially, what you were doing for your client was
covering up the subject matter of the Clarke Advice,
weren't you?
I don't think that's a fair characterisation of it.
I think the -- I think there is a question to be asked
42
the original problem back in 2013 and the decisions Post
Office made around their criminal disclosures at that
point in time.
I want to move on to another topic, which is the conduct
of the Mediation Scheme. I'm just going to take you
to -- I'm going to refer you to a couple of statements
you made in your witness statement. We don't need to
turn them up. At paragraph 149.2 of your statement, you
say:
"If a case went to mediation, a lawyer from WBD
would attend in person to represent POL. I recall
attending two or three mediations personally but
generally this was done by members of the WBD team who
I supervised.”
That's right, isn't it?
Sorry, can you give me the reference again, it hasn't
come up.
Yes, it's paragraph 149.2.
‘SIR WYN WILLIAMS: I think, Mr Parsons, Mr Jacobs was
A
wanting to do this without getting this up on screen but
you want it up on screen so that you can see it?
I've got a hard copy.
MR JACOBS: You have a hard copy. That might save time. So
A
you've got that, haven't you?
Yes.
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l'lljust read at paragraph 253.3 of your statement,
that might involve a bit of rapid page turning on your
part. I'll read it out while you're doing that. You
say:
"I was not of the view that POL were refusing to
engage properly in the mediation process."
Now, my question to you is: you must have been
aware, Mr Parsons, that, in practice, the Post Office
approach to mediations was disingenuous and amounted to
asham. Post Office were not mediating in good faith,
were they?
I don't accept that.
Well, I'll develop my questions to you. Because we've
spoken to many of our clients and let me tell you what
one of our clients, Peter Holloway, has told a us what
happened to him. He says he spent a lot of work
preparing for the mediation, turned up, presented what
he wanted to say, produced lots of documents in support
of his arguments and then everybody went away and the
mediator came back to see him at about 3.00 in the
afternoon, looking tired, Mr Holloway says haggard, and
the mediator apologised to him and he said "Post Office
are refusing to make any offer". He couldn't quite
believe it. He said that "The Post Office
representatives had been sent to the mediation with
45
offers, which were derisory, was they were using the
mediations to strengthen the position of Post Office
against future claims, weren't they?
I think it's fairly ordinary for two parties at
a mediation who reach an arrangement to enter into
a settlement and agreement of future claims.
But making very derisory offers that didn't represent
the sort of claims that were made in the Group
Litigation.
I think two parties to a mediation will always have
different views as to the value of offers put. As
I say, Post Office went into those mediations in good
faith, having considered every case. That was my
understanding.
Well, it's not good faith, is it, Mr Parsons, to send
representatives into a mediation with instructions to
make no offer and not to settle?
Well, I hope I explained that just a minute ago, that
the intention -- I accept that some mediations were
conducted on the basis that there was no mandate to
settle but the intention was to go and hopefully explain
Post Office's position, and it was thought there was
still value in having that conversation.
Can I put to you an explanation of Post Office's
position in the mediations that has already been
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express instructions not to settle at all".
This isn't just Mr Holloway telling us this. We've
spoken to at least a dozen other clients who attended
mediations and they all say that Post Office sent
representatives, Bond Dickinson were there, to
mediations with no authority or instructions to settle.
That's what is what was going on, isn't it?
So each case was assessed on its own merits. Some of
those cases we advised Post Office to settle, some of
them we advised Post Office not to settle. There was
then a discussion internally about whether performance
should still attend mediations where it had no mandate
to settle, and the view taken was that it was
appropriate still to attend those mediations so that the
issues between the parties could be discussed. I can
understand why that would have been frustrating for some
of your clients but it was a decision taken in good
faith at the time.
Well, there were offers made in some cases but our
instructions from our clients are the offers were always
derisory, and we've heard Paula Vennells talk about
token offers, and they were made on the basis that the
subpostmaster agreed not to bring any action in the
future against the Post Office. So, essentially, what
Post Office were doing, in the few cases where they made
46
received in evidence by the Inquiry, and it comes from
Alan Bates. In his witness statement at
paragraph 157 -- and we don't need to put it on the
screen but the reference is WITNO0050100 -- what
Mr Bates says is:
"I believe the Mediation Scheme failed as it was
part of a cover-up by POL. I expect POL discovered
things they did not like and did not want to come out.
There was definitely an element of not wanting to accept
fault. I believe POL had no intention whatsoever of
getting to a mutually acceptable and fair decision. If
anything, it seemed as if POL had been using the scheme
as a fishing expedition to see what evidence
subpostmasters actually had about Horizon."
My question for you, Mr Parsons, is that Alan Bates
is right, isn't he? You supervised this; you were using
the Mediation Scheme in an adversarial way in order to
obtain some sort of tactical advantage against the
subpostmasters?
I don't recognise that description of the Mediation
Scheme. My understanding is Post Office went into it in
good faith with an intention to reinvestigate the 150
cases and, where those cases showed errors on Post
Office's part, it was willing to settle.
My final questions for you: in your witness statement,
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you haven't made any apology or statement of regret for
your actions and many of our clients have been aghast at
the content of the evidence that you've given, the
emails that Mr Blake took you to yesterday.
Sally Stringer is one of our clients and she emailed
Mr Enright, who sits next to me, at 10.20 this morning,
and what she says of you and your evidence:
"His evidence is the absolute epitome of arrogance,
deceit, corporate corruption and is an absolute
disgrace."
I suppose you might think that's quite strong
language, Mr Parsons?
I have apologised within my statement and, to make it
clear, I'll apologise again now. During my time acting
for Post Office, we made some mistakes along the way.
I apologised for them at the time and I apologise to
your clients for them now.
Do you have anything to say for the suffering that Post
Office's advice and your advice to Post Office caused to
clients of ours, such as, for example Ms Stringer and
Mr Holloway?
Unfortunately, I don't know them personally.
I recognise the suffering of some of the subpostmasters
and, to the extent that mistakes I made contributed to
that, I apologise.
49
I defended it along those lines.
That was the mantra, that was the creed, but you could
see that that fundamentalist approach -- you must have
seen that that fundamentalist approach -- had yawning
gaps in it but you didn't confront your client about
that, did you?
I don't think it's fair to characterise it that way.
I think from the start, back when I began, which was
mid-2013, the group that I was working with had in their
mind that there could be another version of events out
there. They believed Horizon was a reliable system but
they were open to the possibility of it not being.
They were open to the possibility?
They were open to the possibility of it and that is why
they decided, in my view, to open up a mediation scheme
to allow subpostmasters to raise those issues.
You know perfectly well why the Mediation Scheme was set
up. You must have gathered that it was Paula Vennells'
idea, "We've been lumbered with this liability by the
Royal Mail Group, let's try and tie it all up, and get
rid of it as cheaply as possible, and avert the risk of
a class action". That's the whole point: it was
grudging; it was insincere; it was cynical.
No, I think it's fair to say that Post Office believed
the Horizon system worked and, therefore, they believed
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MR JACOBS: I just need to find out if I have any more
questions to ask. I may not, but Mr Stein and Enright
will tell me.
I haven't any more questions for you, thank you.
‘SIR WYN WILLIAMS: = Thank you.
Mr Henry, can I invite you to take a break in your
questioning at some point which is convenient to your
line of questioning but which will give the stenographer
a bit of a breather?
MRHENRY: Of course, sir.
Questioned by MR HENRY
MR HENRY: Mr Parsons, on the contrary, I'm going to suggest
2
2
that you didn't make any mistakes at all and that what
you did -- I mean there were errors of judgement,
obviously, there were very serious departures from
standards that ought to have applied, but that what you
did was deliberate. It was clear sighted, it was
ruthless.
Sorry, are you asking me to comment on that?
Yes.
I'm a lawyer acting for Post Office. As a lawyer, it's
my responsibility to defend their interests. For
a large part of my engagement by Post Office, my
instructions were that they considered the Horizon
system to be a reliable system and, therefore,
50
they were in the right position but, at the same time,
the Mediation Scheme was set up, as much as I could see,
with a genuine attempt to understand the complaints of
the subpostmasters and, if possible, resolve them.
Well, then why did you say -- and there's no need to go
to the email because it's already been canvassed by
Counsel to the Inquiry -- why did you say that you
didn't think there was any prospect of settling any of
the cases through the mediation?
As I explained yesterday, that email was set up -- was
sent before the scheme was fully developed and there was
an investigation phase built into it, and my expectation
at the point at which they built the investigation phase
in, is that may give rise to new information which may
cause Post Office to settle some cases. However,
I accept there was a large delta between the parties and
that makes it difficult to settle.
But you say it was a view expressed before it was fully
set up and worked out but, when you look at the history
of the Mediation Scheme, it was a complete sham, wasn't
it?
I don't accept that for the --
It ended in utter failure, didn't it?
I don't believe so. I think it did a lot of good work
investigating 150 cases and I don't have the statistics
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before me but, in a good number of cases, settlements
were reached.
Q. I want to go back now, very briefly, to 9 September
2013, and just help us, please. I don't quite
understand your evidence. What are your memories of
that consultation that took place at 2 Bedford Row?
A. I recall there was a consultation, I can recall being in
2 Bedford Row chambers in the room but I can't really
recall any of the details of what was discussed.
Q. Oris it that you don't want to, Mr Parsons?
A. I'm afraid it was a long time ago and I just can't
recall the details.
Q. Along time ago, of course, but let's not forget the
context. I mean, you were involved in arranging that
consultation together with Mr Matthews, weren't you?
A. Primarily it was Mr Matthews but I accept that.
Q. Yes, and it was a very, very serious problem that you
had because you had the coalescing of the Second Sight
Interim Review and then the revelation, of course, of
Gareth Jenkins and the Clarke Advice. You were made
aware of the problems with Gareth Jenkins, you say, from
about 8 July and you read the Clarke Advice on 17 July,
correct?
A. Correct.
Q. Right. So there must have been quite a lot of
53
going to be taking many notes!
Then there was Susan Crichton, she was General
Counsel, rather too senior, perhaps.
There was Rodric Williams: was he scribbling?
A. My general recollection of Rod is he was someone who
made notes. I can't recall if he was in that meeting.
Q. You would recognise his handwriting?
Maybe.
Q. Maybe. Mr Clarke was there, Mr Bowyer was there,
Mr Smith was there. We know that Mr Smith was writing
notes and then he typed them up. Your partner was.
there, Mr Matthews. You, however, were the senior
associate, you would have been the deputed notetaker,
wouldn't you?
A. I don't recall being asked to take notes in that
conference. I haven't being able to locate any of my
notes from that conference.
Q. You haven't?
A. We've had a look, I --
Q. Whata shame. I wonder where they went to.
‘SIR WYN WILLIAMS: Well, hang on: he hasn't accepted that he
made notes, Mr Henry.
MRHENRY: You've looked for you -- you say you've looked?
A. We've tried to locate my old notebooks.
Q. So would you have been doing it on to a computer or
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expectation and anticipation. I mean, "How is the great
man, Mr Altman, going to get us out of this mess?" You
must have been thinking like that. I mean, you did want
to advance in your profession, didn't you?
As I've said before, I wasn't advising on the criminal
side but it's fair to say I was interested to understand
what Brian's advice was going to be.
I'm sure you were interested, and why were you
interested?
Because it was a serious issue.
Yes, and that serious issue will have impacted with the
civil cases that you were trying to keep at bay.
I didn't see it that way at the time, though I ~
You didn't?
-- though I recognised there was a crossover between
subpostmasters who had been criminally convicted and the
civil claims they might then subsequently bring --
Are you really saying to the Chairman of this Inquiry
that you didn't see it that way at the time?
It wasn't the way I was thinking about matters.
Well, we'll come to that but let's just concentrate on
who was there. Can I take it that you were the most
junior person in the room?
Yes.
Now, Mr Jarnail Singh was there, and I don't think he's
54
would you have been actually writing it out?
I suspect, back at that time, I would have taken notes
on paper.
Right. I mean, it's not an invariable practice but
often the most junior person in the room, the senior
associate in your case, would be the notetaker because
they're the least involved in the discussions and they
are, more or less, observing events and so, therefore,
they are there to take an assiduous note. Are you
saying that you have no recollection of note taking?
I have no recollection of taking notes in that meeting.
Right. I mean, obviously you would have wanted to have
been diligent and you would have wanted to have
impressed, wouldn't you?
Well, at that time, impressed who?
Well, your partner and the other people in the room.
I mean, you were a senior associate. Presumably, you
had designs on partnership?
At the time, Gavin Matthews was the partner in the room.
I knew him well and, as I explained, he was leading on
that line of work.
Right. Well, I want to come, please, to those notes
because I'm going to suggest that the ones that were
preserved by your firm were sanitised. You've already
been taken to the point that there is no mention of
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shredding. Do you have no recollection of shredding
being mentioned?
No.
There's no mention of "other Misras crawling out of the
woodwork". Do you remember an expression of that kind
being used by leading counsel?
I don't recall that.
No. It's a rather unfortunate expression, isn't it?
I don't really have a view on it.
You surely -- I mean, are you saying that you have no
recollection of that?
I have no recollection.
No mention of a direct question post by your partner
Gavin Matthews, "Should we apologise to Seema Misra?"
and leading counsel saying, "! wouldn't"?
I don't recall that.
And curiously at all, no mention at all whether, in the
circumstances, there should be prompt disclosure to
Mrs Misra of the discreditable conduct and breach of
court duties of Gareth Jenkins.
If that's what the minute says, that's what the minute
says, but I don't recall those discussions.
No, I'm saying that there is no mention of it at all
and, surely, Mr Parsons, in a case where the Post Office
has relied upon Mr Jenkins as to the efficacy of the
57
Mr Chris Aujard, and it was in connection with
Linklaters being approached, and the document I want to
put up is POLO0006484. You're familiar with this
document?
I'm aware of it.
You were aware of it enough to forward it to David
Oliver and Chris Aujard when they were considering the
appointment of Linklaters, and I suggest that this shows
what was really in the background all the time, which
dictated the actions that you and others, Mr Parsons --
because it's not just you -- that you and others took.
So I want to go to the second bullet point. It is
reported that leading counsel, Mr Morgan, sai
"The proposal to instruct an independent expert to
prepare a report on the Horizon system is the highest
risk response to the issue. What will it achieve? It
will not be able to address any of the civil/criminal
cases dealt with under 'Old Horizon’ [so that would be
Legacy Horizon]. Will it seek to review particular
cases? If so, which ones?"
So immediately there, there is identified the
problem of pre-2010 cases; do you agree?
Correct, yes.
Next bullet point:
"Whatever the findings of the expert report it will
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Horizon system, they would be bound to disclose material
which undermined his status as an expert witness,
wouldn't they?
That was a matter for the criminal lawyers to advise on.
No, Mr Parsons. You're a lawyer. You were heavily
involved -- and we'll see how heavily you were involved
when I ask you further questions about this in the
instructions of Mr Altman -- and you had a brain.
I put it to you again: in a case where the Post
Office has relied on Mr Jenkins as to the efficacy of
the Horizon system, they were bound to disclose material
to Mrs Misra which undermined his status as an expert
witness?
That's what I understand the position to be from the
criminal lawyers.
Yet there is no mention at all in the minutes, no
mention at all of that being discussed. Do you find
that odd?
Yes, I do find that odd, given that that was probably
the -- one of the key issues that was under review at
that point in time.
Yes. Now, I want to come, please, to a document that
you sent under cover of an email which we don't need to
get up but, just for the sake of the record, it's
POL00021991, and you sent it to Mr David Oliver and
58
not resolve the problem. [The Post Office] will be
‘damned if they do and damned if they don't’. If the
findings are that there are no issues with Horizon
people will see that as a ‘whitewash’ whereas if the
findings are negative, that will open the floodgates to
damages claims by SPMs who were imprisoned for false
accounting and Access Legal will start to pursue all the
civil cases they are currently sitting on."
Now, can you just help us, please, who were Access
Legal; were they a funder?
SIR WYN WILLIAMS: No, I think they were Shoosmiths by
another name, weren't they?
MR HENRY: I'm very grateful, sir. Thank you.
So Shoosmiths, part of which Shoosmiths was one
firm, part of a conglomerate of solicitors’ firms,
a network of solicitors firms; is that right?
A. That's my recollection, yes.
Q. Right. So if the findings are that there are no issues
with Horizon, it's a whitewash; whereas, if they're
negative, floodgates. That was a matter, as well, that
you were aware of, that there was a dam and, behind that
dam, there were hundreds, and hundreds, and hundreds,
perhaps, in fact, thousands of subpostmasters who were
the victim of unjust claims for compensation by the Post
Office in respect of fictitious losses, and a lesser
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number, but still in their hundreds, of people who had
either been convicted or had been, through force of
circumstance, forced to plead guilty to, as the example
is given there, false accounting.
Just as a point of context, this note is from June 2012.
I didn't become involved until nearly a year later.
I don't recall when this note was first provided to me.
As to your question, I think it was always known by
people at the Post Office and the Legal Team that, if
Horizon was found to be fundamentally flawed, that would
lead to a large, wide range of legal liabilities.
So whether you actually had personal knowledge of this
note or not, it reflects, nevertheless, what would have
been the concerns to of the Post Office and also the
concerns of Gavin Matthews, who was handling the Post
Office Account?
I think it's an almost natural consequence: if the IT
system was found to be fundamentally flawed, there would
be a wide range of legal liabilities.
Yes. That's why I suggest you are part of the policy of
keeping it all at bay. To put it in a nutshell: delay,
deny, get rid of the judge, if you have to, but keep it
all at bay. That was part of the policy that you signed
up to, at Bond Dickinson.
I don't accept that. When I began in 2013, the
61
"Very clear proof of technical defect in Horizon.
"Risks
"[The Post Office] should be slow to concede that
Horizon has any technical faults."
I thought you were saying they thought it was
robust?
They believed at that time it was a reliable system. It
had obviously, at that point in time, already disclosed
the three known bugs, at that point in time. As
l accepted yesterday, I think the bar that is set there,
on reflection, is now too high.
But look what you say, "to do so could open up the
floodgates to a large number of claims". They must have
been within your knowledge; you must have known that
they were behind the damn.
As I said before, if -- it was always known to me, and
I suspect others at Post Office, that, if there was
found to be a fundamental problem in Horizon, that
affected a large number of subpostmasters, then that
would open them up to a large number of claims.
Then, of course, you put it in terms like this: it would
be almost impossible to reverse this position if
conceded. I'm going to use the term “domino effect”; if
the pin comes out of the grenade, then you can't predict
where the shrapnel is going to end up?
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instructions I had is that Post Office believed the
system was reliable. Second Sight had just concluded
their Interim Review and found that there was no
systemic problem. The basis on which we operated was
that understanding. That understanding is obviously
wrong but it wasn't understood to be wrong at the time.
Now, do you remember, when I asked you to consider your
mindset when you went to that consultation on
9 September 2013 about whether you had concerns about
floodgates and civil claims if criminal prosecutions
were undone, and you said it wasn't operating in your
mind at the time. There's no need to get it up but you
do remember that, not that long after that, on 8 October
2013, you made a presentation to the Sparrow Working
Group, didn't you?
I may have done. If you can help me with -
You were taken to it yesterday. If need be, if you'd
like to see it again, we'll get it up on the screen.
It's POLO0022002, and it's page 14 of that document.
Mr Blake took you to it and I think it's page 14. I do
hope I'm right about that.
Yes. There it is:
"Horizon inaccurately records data/transactions.
"Recommended threshold of proof before offering
a remedy.
62
The concern at this time was that there was some
underlying fault in Horizon that was causing a wide
range of losses that could explain the subpostmasters'
concerns. Now, we had no evidence of that at the time
and that's what we were concerned to understand and
that's what that's a reference to.
Did you like Second Sight?
On a personal level, yes.
Just help me with this because it may be that I've got
the wrong end of the stick but could we go to
POL00021686, and could we scroll down, I think it is.
I always say scroll up but if we could scroll down.
We've got 15 February 2016, you to Mr Bourke,
Mr Underwood, Rodric Williams, copied Daniel Fawcett:
"Patrick, Mark, Rodric
"[For you information] below. Dan found this in the
[Second Sight] emails. It looks like [Second Sight]
feeding questions to Alan for use with MPs."
If we scroll up, we can see that Mr Fawcett has got
access to, for example, emails from Chris Holyoak to lan
Henderson, Ron Warmington; who is Daniel Fawcett?
He's one of the lawyers at Womble Bond Dickinson.
Was he junior to you or of the same -- you were
a managing associate at the time, I think?
Scroll up, please, so I can see the date. I would have
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still been a managing associate then. I think I was
made up to partner on 1 May 2016.
So how did you get hold of these Second Sight emails?
At the end of the Mediation Scheme, Second Sight was
asked to return all its emails to Post Office for
safekeeping.
Was there any confidentiality implied in the return?
Not in --
In other words, that they were, you know, returned but
nevertheless remained confidential?
I don't recall any.
Right. So this is after they've left the scheme. What
were you trying to do, accumulate dirt on them?
No, It was just an observation I'd made to others at
the Post Office. As I explained yesterday, one of the
concerns I had about Second Sight is I felt that they
were leaning too much in favour of the subpostmasters,
and had lost some of their neutrality. I think
I probably forwarded it because that email seems to be
evidence of that point.
Who instructed you to do this? I say "you", of course
it was done by Mr Fawcett but you're forwarding his
product. Who was instructing you to do this?
Sorry, to review Second Sight's emails, do you mean?
Yes.
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we want to go to the next one. Yes.
Then there is an email from you, if we could keep on
scrolling down, please -- further, please. I'm so
sorry, I'm not finding the part. There is an email
where you say that you "gently warned" Mr Ron
Warmington. So if we could just go and see that. It's
in the body of this email. It's page 2., yes. Thank
you so much.
It's the penultimate paragraph:
"Ron is going to write a response to Post Office
along the above lines. I have gently warned [Ron
Warmington] that he needs to be careful about anything
he says in relation to criminal prosecutions as such
comments are under heavy scrutiny and will have
consequences.
"... he is now more comfortable with how to handle
the situation. Hopefully, [the Second Sight] letter
will close down the issue."
Can you help, please: who was heavily scrutinising
Mr Warmington's comments about criminal prosecutions?
I don't think it was specifically aimed at
Mr Warmington's clients, he --
Well, then why did you "gently warn" him?
So my recollection, and it is rather dim now, is that
Mr Warmington had said at a meeting that he had material
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I can't recall the context here I'm just looking at the
subject line, which says "POL DSARs -- SS Docs". If
I remember, there was a period around 2015/2016, where
Post Office received a lot of data subject access
requests from subpostmasters, so it may have been they
were being reviewed in that context.
Well, let's go, please, now to POL00413924. We can see
that the heading "Second Sight -- disclosure information
to [the Post Office] on prosecutions", Mr Jarnail Singh
forwards it. Could we scroll down, please, and could we
scroll further down, please. Yes, there we are:
"andy
"This was a formal request and needs to be dealt
with formally by Second Sight. As [Mr Altman] advised
it can then be reconsidered. If then Second Sight still
feel uncomfortable dealing with our request for
disclosure, we may ask them to provide a witness
statement to clarify their position on disclosure."
So this is trying to obtain information from Second
Sight, is it?
I believe the context to this is that, at a Working
Group meeting, I think it was, Second Sight had
indicated that they believed they had evidence that was
relevant to prosecutions.
Yes. Can we just scroll up, please, or scroll down —
66
that he thought was relevant to prosecutions. That had
caused Post Office to respond to that and discuss
whether they then needed to get access to that
information, what they were going to do with the
information if he did have it, et cetera, et cetera, but
the output of this, actually, is Mr Warmington accepted
he didn't have such information or at least he didn't
have any new information.
And so the point of the conversation with Ron was
that -- to say to him he needs to be careful of what he
says because he'll set hares running on these points
which causes a lot of work to be done, in this case,
actually, for no purpose at alll.
Why didn't you say that? Why have you said instead
"I gently warned him that he needs to be careful about
anything he says in relation to criminal prosecutions as
such comments are under heavy scrutiny and will have
consequences"?
I've given you my explanation for it, which is, if
comments are made by people at this time that they
believe they had material relevant to prosecutions, that
was something Post Office was alive to and they needed
to do something about.
At its most anodyne, this was an attempt to steer Second
Sight away from their interest in criminal cases, the
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investigation of criminal cases and the prosecution of
criminal cases, wasn't it?
No, it wasn't.
At its worst, it has all of the appearances of a threat?
No, it wasn't. I don't believe it was and I believe
there is a letter, actually, from Second Sight at the
end of this somewhere --
Was this is an attempt to close the lid on potential
criminal appeals that might be caused by, to use the
expression, "careless lips costs ships", or, you know,
blurting out something which might then be used by
a prospective criminal appellant?
Not at all. In fact, I think it's the opposite.
I think Post Office heard something in a meeting and
acted diligently to figure out whether that was
something of substance.
What about the hare that you said this could set
running?
In terms of work being done in this case for no purpose
because I believe the output is that Ron decided he
didn't actually have any material.
We saw that you're quite good at closing things down.
I mean, for example -- no need to take you to it but
Mr Blake took you yesterday to what you described as
"high-level advice", which shut down the Lessons Learned
69
1.
-- the ambit of his instructions?
I recall there was a terms of reference and there was
some discussion about them but, as I explained
yesterday, I don't believe I had substantial involvement
in them.
Well, I want to go, please, to POL00297951, and this is
you to Mr Rodric Williams, copied to Mr Matthews,
regarding Mr Altman:
"... Brian looks like the right man for the job. In
my view he was very impressive.
"He's clearly undertaken this type of exercise
before and is very live to the political dimension."
Which was?
At that time, Post Office was under pressure from
a group of MPs following the publication of the Second
Sight review.
And the Post Office must not fail?
I don't recognise that comment.
"Big question -- is Brian's work private advice for [the
Post Office] or an independent assessment of [the Post
Office's] criminal law position? One for us all to
think about."
There, your partner -- when I say your partner, the
partner above you because you hadn't yet been made
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Review, or, if it didn't shut it down, it diluted the
Lessons Learned Review because you were concerned about
proactive disclosure in criminal cases. You remember
that, you were taken to it?
I remember the document but I think it's important to
remember that the instruction we had was to point out
the risks. We weren't asked to give an opinion on
whether it should go forward, hence why my email
contains a series of negative statements and risks.
You also, I suggest, were quite astute in positioning
Mr Altman so he did not feel it incumbent upon himself
to point out a flagrant miscarriage of justice.
I don't recall any such conversation with Mr Altman and,
as I tried to explain yesterday, I don't believe I had
substantial involvement in Mr Altman's terms of
reference.
We saw yesterday, of course, Mr Matthews saying that
Mr Altman should not opine on safety but wasn't there
also a debate as to whether his advice should be private
or public?
I recall that as a topic that was discussed.
Wasn't there also some fudging about the fact that,
although he was being instructed by Bond Dickinson,
there was toing and froing as to establishing his terms
of reference --
70
a partner, had you?
No, not at this time.
No. The partner above you is being copied. Then you
say:
"Short-term -- Brian is going to assist with the
response to the CCRC."
Would that be the holding response?
I can't recall now where we were in the --
It must have been the holding response, mustn't it?
It may well have been but, as I say, I can't recall the
exact sequence of letters.
“Longer term -- we need to draw up some terms of
reference for his work. Gavin and I will have a first
stab at this and then circulate this to the team."
Then could I ask you, please, could we go to
POL00298123 and could we go to page 2. This is, of
course, signed off by Gavin Matthews:
“Our advice is:
"[The Post Office] legal needs to disclose Brian
Altman's interim review to [Cartwright King] and discuss
it with them.
"[Cartwright King] should be asked to respond in
writing to the recommendations made at paragraph 24 and
paragraph 15."
Then this:
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"Bond Dickinson [that's you] should sit down with
Brian Altman to walk him through the spot review process
and the [Second Sight] Report so that he can understand
the impact of his review on the civil side."
Help us about that, Mr Parsons. What does that
mean?
A. I think Brian wanted to understand more about the Second
Sight Report and the spot review process. I don't
understand the comment at the end about the impact of
his review on the civil side.
Q. You don't understand that comment?
A. I can understand that, if any of the convictions were
found to be unsafe and overturned, it would have civil
liabilities for Post Office but I don't know what Gavin
had specifically in mind with that comment.
Q. It's all about the dam again, isn't it?
A. As I've accepted, my view at the time, and I believe
others at the time, accepted that, if Horizon was to be
found to be fundamentally flawed, it would give rise to
potential legal liabilities.
Q. It would only take one successful criminal appeal where
there was proper, candid disclosure, in accordance with
the law, and the whole dam would collapse, wouldn't it?
A. I don't recall thinking about things that way at the
time.
73
(A short break)
(12.05 pm)
SIR WYN WILLIAMS: Ready when you are, Mr Henry.
MR HENRY: Thank you, sir.
Mr Parsons, solicitors have a fundamental duty to
act in a way that upholds justice, do they not?
A. Alongside a series of other ethical duties, correct.
Q. You don't suggest, by saying that, that that fundamental
principle is, as it were, subject or dependent upon the
other principles?
Let's reflect upon it: solicitors have a fundamental
duty to act in a way that upholds justice. Yes or no?
A. Itis one of the duties. There are other duties as
well. I don't think those duties necessarily need to be
incompatible with one another.
Q. Now, just help me, please. Who was giving the advice in
relation to the redaction of Gareth Jenkins' name? Do
you say that was not your responsibility?
A. Are you talking about the Helen Rose Report?
Yes.
2
A. No, I don't believe it was my responsibility. It was
redacted by Cartwright King.
Q. Anybody else?
Not as far as I am aware.
Q. Did you ever gather anything at all from Mr Altman about
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Q. But you don't understand, you say, so that Mr Altman can
understand the impact of his review on the civil side.
You tell the Chairman that you don't understand what “on
the civil side" means?
A. No, I think I've tried to explain that I understood
that, if a conviction was found to be unsafe, it would
give rise to civil liabilities. That's my general
understanding of the interrelation of those, of the
criminal side and the civil side. What I said is
I didn't understand what specifically Mr Matthews had in
mind when he drafted that sentence.
Q. I want to try and deal, please, with one, if the
shorthand writer, can cope with another ten minutes, I'm
very grateful, sir --
SIR WYN WILLIAMS: Well, hang on, Mr Henry. When you say
another ten minutes, does that mean you'll finish?
MR HENRY: No, sir, because I think I started at 11.20.
SIR WYN WILLIAMS: Sure, I think it was a little earlier but
never mind. I think, I'd prefer to take a break, if you
don't mind.
MRHENRY: Certainly, sir. Certainly.
‘SIR WYN WILLIAMS: We'll start again at 12.05, and then you
can keep going, so to speak, until about 1.40, 1.45.
MR HENRY: That's very kind of you, sir, thank you.
(11.50 am)
74
what was to be done with Mrs Misra?
A. I don't recall Brian advising on anything specific with
Mrs Misra but that may simply be, because so much time
has passed, I can't recall it.
Q. We know he was advising on 9 September 2013 that she
should not be involved in the mediation process and the
reason for that was that it might give her a ground of
appeal, was it not?
A. I recall the criminal lawyers, both Cartwright King and
Brian, both voiced objections to subpostmasters with
convictions participating in the scheme.
Q. I'm talking about the actual name of Mrs Misra being
raised in that specific context, not just convicted
people but Mrs Misra herself. It's in the note.
A. Itmay be. I don't have it in front of me. I'm just
saying I can't recall that now.
Q. But you do recall -- well, you've already agreed with
Mr Blake. I won't need to go further.
What happens if a criminal lawyer is giving advice
which you don't understand or which you consider to be
wrong? That would surely put you under a duty to do
something about it, wouldn't it?
A. _I--if I had such awareness, I would, yes.
Q. You've already confirmed that you did have such
an awareness because you don't dissent from the
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proposition I put to you that, if the Post Office relied
‘on Gareth Jenkins as a witness to convict any particular
person, they would be bound to disclose material which
undermined his status as an expert witness.
That was my understanding from the criminal lawyers,
yes.
Right. Okay. Well, I want to now deal with Mrs Misra
particularly, and could we go to WBON0000746. This is
you to Mr Williams, to Mr Pheasant and also to
Mr Matthews:
"I think I've pinned down what happened with Misra.
"This was a criminal case. We subsequently reviewed
transcripts of the criminal proceedings to identify
anything relevant to Horizon ...
"[Attaches a memo, key findings].
"3 tables with detailed cross-reference to the Misra
court transcripts identifying all the relevant
material.”
I omit words.
"... having re-reviewed these documents, I can't see
anything that looks like the 14 Bug, the 62 Bug or the
Falkirk Bug. However, it does appear that the Misra
case went through Horizon in detail."
Can we now turn, please, to -- well, insofar as you
can, by the 1 July, you got up to speed with Mrs Misra's
77
But the rest of the document isn't in my firm's house
style, so I can't now recall the provenance of the
document.
It's got a "4A" reference, which is exactly the same
reference that was put on the "Horizon Risks" document
which at one point you thought had gone to the Board and
served the dual purpose of advising the Board and also
notifying the insurers. So that's your firm's
reference, isn't it?
It looks like my firm's reference.
Right. So can we just go to page 2 of this document,
please, paragraph 8, in brackets:
"We believe [James Arbuthnot] may feel that any
interim findings which disclose any issue with Horizon
should result in past criminal prosecutions by Post
Office Limited being reopened and overturned."
Paragraph 19, on page 4, please. You're dealing
with "The 2 Anomalies" there, the 62 branch,
paragraph 20, page 5, the 14 branch, and then could we
deal with paragraphs 30 to 32, please, on page 6. Now:
"The Falkirk Anomaly was the subject of evidence in
the ‘Misra’ criminal prosecution, where:
"the defence expert asserted that its existence
demonstrate that Horizon had faults which could cause
losses, and therefore that possibility could not be
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case?
No. I think this was -- work was undertaken by
an associate in the team, and it was undertaken to
specifically look for references to bugs, and so it had
a very narrow remit as per the instruction we had
from --
But look at the materials referred to, a memo of the key
findings, three tables with detailed cross-references,
et cetera, et cetera. I mean, you said at the outset,
"I think I pinned down what happened with Misra".
Yes. Based on those documents, I would have read them
at the time to identify the question we were being
asked, which is was there any references to bugs? I do
note and just want to correct there, "I can't see
anything that looks like the Falkirk bug". I think the
Falkirk bug was referred to in Misra and that was
a mistake.
Quite right. POL00111625, please. Can we make the
bottom left-hand corner -- can we focus on the bottom
left-hand corner. You drafted this, didn't you?
This document was provided to me at the start of today,
so I've not had a chance to look into it. Though I note
the bottom left-hand corner has a reference that looks
like my firm's reference.
Yes.
78
excluded in Misra's case.
"The prosecution expert (Gareth Jenkins from
Fujitsu) asserted that it could not have been
responsible for the losses because its clearly visible
events had not manifested themselves in the branch
records, and that it had been fixed more than a year
earlier.
"Misra pleaded guilty to false accounting, and was
convicted by a jury of theft. To reach this verdict,
the jury had to be satisfied that the charges were
proved beyond all reasonable doubt. She was sentenced
to 15 months’ imprisonment. There has been no appeals
against conviction.”
Of course, anybody reading that and anybody
preparing that document would realise that, in order for
her to be convicted on theft, the jury would have had to
have been satisfied, as it says, beyond all reasonable
doubt; and who was the prosecution expert? Gareth
Jenkins.
Now, you were aware, as you've already said today,
from paragraph 87 of your witness statement, of the
Gareth Jenkins problem from 8 July and you received the
Clarke Advice on 17 July 2013 from Susan Crichton. You
read this document, didn't you? Did you prepare it or
were you part and parcel of preparing it?
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As I say, I haven't had a chance to investigate it
because I was only provided a copy this morning. It's
got our reference on it, which means it probably was
sent to us at some point in time at least. I can't now
recall whether -- what input I may have had into it or
not.
Could investigations be made into who was the author of
that document; is that what you're saying?
It might be possible.
Right. Well, Mr Parsons, Mrs Seema Misra and her
lawyers should have been provided with information of
Gareth Jenkins' misfeasance as soon as possible after
that misfeasance came to light, shouldn't they?
Looking back on it now, that seems -- that would be my
view but, at the time, that was being advised on by
Cartwright King and Brian Altman, and I followed their
advice.
What about your fundamental duty to act in a way that
upholds justice?
At that time, I wasn't aware that there was any problem
with what -- the choices the criminal lawyers had made.
Can we just focus upon that because, of course, you've
read the Clarke Advice, you are alerted to the problem,
at least a week before -- or slightly more than a week
before you read the Clarke Advice. Mr Jenkins,
81
I haven't got it in front of me but I don't recall that
he was mentioned in it.
You accept that, don't you, he's not mentioned at all?
That's right.
That letter is indefensible because of that omission,
isn't it?
No --
It gives false reassurance to the CCRC?
At that time, it was just intended with a holding letter
with an intention that further correspondence would
follow about these issues.
The omissions -- and I've no need to repeat them, you've
accepted what they are -- the omissions are
indefensible, aren't they?
Which omission are you referring to, Mr --
Well, that Gareth Jenkins was in breach of his duty to
the court, that "Oh, by the way we know he gave evidence
orally and in writing in numerous cases, which is said
to be misleading and he hasn't acted in accordance with
his obligations mandated by law, and the Criminal
Procedure Rules, Rule 19. Instead we've appointed Brian
Altman in relation to the Second Sight Interim Review",
and you continue to trade off Brian Altman's reputation
going forward as well, don't you?
That isn't how I recall the events. My recollection is
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an unreliable witness, correct?
Correct.
Post Office could no longer call him because his
credibility was shot, correct?
Correct.
Failed in his duties to the court?
That was the advice from the criminal lawyers.
Said to have given false or misleading evidence in the
cases in which he was involved?
Again, that's from the advice from the criminal lawyers.
And you knew he had given oral evidence against
Mrs Misra?
\ did.
Right. Isn't it obvious that the substance of the
Clarke Advice, the facts which were not cloaked in
privilege, should have been stated clearly to the CCRC
in the holding letter you drafted?
At that time, I was just drafting a holding letter
whilst Post Office sought advice from their criminal
lawyers.
It seems, however, in that holding letter, that the Post
Office is trading on Brian Altman, all in the context of
the Second Sight Interim Review, but the tainted
witness, the unsafe witness that gave evidence against
Seema Misra isn't mentioned in that CCRC letter at all.
82
that Post Office was seriously concerned about the
Clarke Advice and Gareth Jenkins’ past testimony. That
is why they instructed Brian Altman, to give them a view
that they were doing the right things in response to
that situation.
They were seriously concerned because the facts are
dealt with in the Clarke Advice and the Clarke Advice
itself is the pin in the grenade and they wanted to keep
the pin in the grenade, rather than the grenade going
off; that's the truth, isn't it?
Not as far as -- not that I can recall at that time but
I wasn't sighted on the decisions that were made on who
should get what disclosure and what disclosure should be
given.
Well, you actually are concerned sometimes in cases and
you actually query Mr Clarke -- we'll come to it if
necessary -- and say, "Well, shouldn't this be given?"
I saw that as the role of Cartwright King under the
supervision of Brian Altman.
Right. Advice is given, and you give this advice, that
the report -- that's Mr Altman's general review -- gives
good grounds to resist any formal external review of the
Post Office's historic prosecutions, ie by the CCRC --
that document is POL00123004, I don't need to take you
to it -- but no one is mentioning Seema Misra, are they?
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Do you mean in that particular document?
Yes.
I don't recall her being mentioned in that document.
No. Again, an indefensible position. The advice is
given that the report gives good grounds to resist any
formal, external review, yet all of that rottenness, all
of that taint in relation to the architect of the system
and the expert that the Post Office had used is
airbrushed from the picture. It's deliberate, isn't it?
No, not as far as I can recall. My understanding was
that Post Office thought that, if Cartwright King were
to make the correct disclosures in the cases having
undertaken their review and that Brian Altman had
reviewed that process and agreed that it was a sound
process, and that was information -- information was
provided to the CCRC, the CCRC may then decide that they
don't need to undertake their own investigation. And,
of course, Brian Altman's advice was provided to the
CCRC, admittedly later, but at the beginning of 2015.
What you're getting, in fact, is layer upon layer of
external lawyers giving the vestige of respectability
but, at the heart of it, buried underneath all of this,
is the fact that an obvious disclosure decision, to
disclose to Mrs Misra's lawyers, is never taken so far
as Gareth Jenkins' misfeasance?
85
case, as in there could be many of them but it might
undermine them.
But he did give evidence orally in only one case but
let's contrast that, because the contrast is even more
pronounced, if we go to POL00040026, and this is the
draft which you said was I think unacceptable because it
was apparently misleading. Could we go to the same
section, "Prosecution", please.
Yes. There, "Prosecutions & Convictions", second
paragraph:
"Post Office has an obligation to consider whether
further discourse [it should be disclosure] should be
made to defendants. It is of concern to Post Office
that the expert evidence of one prosecution witness,
Dr Gareth Jenkins of Fujitsu, may have failed to
disclose certain problems in the Horizon system
potentially relevant to a case."
There can be no doubt there: that is singular and
that is referring, is it not, to Seema Misra?
It definitely seems to be singular. I don't know what
it was referring to because I think it appears that
those amendments were made by the either Rodric Williams
or Cartwright King.
Yes, and that's clear, because it has been done, and
there's no need for me to take you to it, but I'll give
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That appears to have been the case but, as I say,
I wasn't involved in that decision at that time.
I want to come very briefly to the comparison of your
“Horizon Risks" document and the document that Mr Rodric
Williams was involved in. If we can get up your
document, which is POL00021996, and if we could go to
the prosecution risks chapter or section, please, the
second page. "Prosecutions & convictions", and we'll
take it as read that that second paragraph, "In
particular, the expert evidence ... Dr Gareth Jenkins of
Fujitsu", and we can see that there is, in the last
sentence:
may have undermined a prosecution case or
assisted with an accused's defence."
Forgive me, sir, I'm just looking at a reference.
Right.
Do you see there, even you have put "a prosecution
case":
may have undermined a prosecution case
Yes, I can see those words.
Singular. That's a reference to Seema Misra, isn't it?
I don't believe so. I think you're reading it
differently to the way I'm reading it. I don't think
I'm reading that as there has been a single prosecution
case, as opposed to it could undermine a prosecution
86
the reference for the transcript, POL00040025. That was
done after amendments by Rodric Williams and Cartwright
King.
But, paradoxically, although it would have appeared
to have been misleading, it made it clearer that that
one case must refer to the only case in which Mr Jenkins
gave oral evidence: the case of Seema Misra?
It seems a fair possibility but I don't know for
certain.
Itdoes. Now, Cartwright King -- clearly an appeal is
on the cards because the amendment is 26 August 2013.
That's the email back to you, which says, "This has been
done with amendments by me and Cartwright King”.
So that suggests that there may be an appeal in the
offing, hence the disclosure to the insurers.
5 October, there's a document drafted by Cartwright King
that she was due to receive disclosure, Mrs Misra, that
disclosure ought to be given to her. But then we have
to fast forward to January 2014 and a decision is made
that she isn't to get disclosure.
Do you have anything to say about that?
I was unaware as to the decisions made in relation to
individual cases as to who got disclosure and who
didn't.
I suggest that 21 October could be a key date in
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understanding this. No need to get it up on screen but
you were taken it to yesterday and Counsel to the
Inquiry, Mr Blake, linked two documents. One was
POL00372551, which was Ms Vennells to Alice Perkins,
talking about the unsafe witness, and then there's
another one, you writing to Andy Holt, Gavin Matthews,
Belinda Cortes-Martin and Jarnail Singh, and it's
POL00123004, and perhaps we should get that up on the
screen, please. Could we scroll up, please.
This is from you -- and scroll up -- scroll down,
sorry -- and scroll up. Yes:
“Brian Altman's ... First Review has now been
received."
Again, no mention. It's the same day as Ms Vennells
talks about the unsafe witness but no mention at all by
you of the Gareth Jenkins problem, is there?
No, at that time I presume that everybody receiving this
would have been aware of the Gareth Jenkins problem
because it had been raised some months before.
But it's always a sensible idea, in considering this
whole issue, about whether there are good grounds to
resist any formal external review of its historic
prosecutions, to mention one thing which eminently
qualifies for investigation and review by the CCRC,
which would be the Clarke Advice.
89
the grounds that Horizon was not a reliable system would
have been seriously damaging for Post Office.
In fact, the very document that caused Mr Justice Fraser
so much concern, a Fujitsu document which talked about
the receipts and payments mismatch bug and the insertion
of data, Solution One, Solution Two, Solution Three,
which ought to have been disclosed in Mrs Misra's trial,
I mean, it would have made it incredibly difficult to
defend the Horizon Issues trial, wouldn't it, as well?
If it's —- if we're thinking about the same document
I understood that document had been provided to Second
Sight, I believe, if we're talking about the same
document. So the document was out there with them to
investigate at the time, yes, if it was the document I'm
thinking about, then it was referred to in the Horizon
trial.
So what I'm going to suggest instead, this is my last
topic and I've got a quarter of an hour, is that,
instead, a rationale for limited disclosure was devised,
namely the provision of the Helen Rose Report, because
it potentially revealed Mr Jenkins to be unreliable
based on his knowledge of system errors, which he did
not reveal, and you knew that, of course, because you'd
read the Altman general review, hadn't you?
I was aware of the problems with Gareth Jenkins’
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As I said, I assume that the recipients of this would
have all have been sighted on the original issue that
was raised in the Clarke Advice.
Now, you're familiar with the issues, you've already
given evidence about them, but, if Mrs Misra had had
prompt disclosure, she would have had an unstoppable
appeal and her appeal would have exploded not only
Mr Jenkins but also the Post Office's management of
Mr Jenkins, wouldn't it?
I can't comment on how her appeal may have gone but it
seems to me that she would have had grounds to appeal
and that would have had -- and, had she been successful
in that appeal, it would have had serious knock-on
consequences for Post Office.
We take the terms of the Inquiry, of course, by
reference to the Horizon Common Issues, the Horizon
Issues and also the Hamilton appeals. But it would have
also blown up remote access because of material
non-disclosure of documents known to the Post Office in
2010, in relation to remote access and insertions of
data to resolve the receipts and payments mismatch bug,
which ought to have been disclosed to her as well. So
it would have been catastrophic for the Post Office,
haven't it?
An appeal -- a successful appeal against a conviction on
90
evidence.
Yes, and I'm going to give the reference -- no need to
take you to it, but it's POL00006803 at page 54 --
because in the Altman general review, there is
a reference to that and how the Helen Rose Report might
have a potential for an impact on Gareth Jenkins’
credibility.
Now, in paragraph 183 of your statement, you relate
a conversation you had with Mr Simon Clarke -- whether
the conversation was oral or in writing I don't think is
clear -- but paragraph 183 of your statement at
page 110, I'm just going to quote the last sentence:
"He [Mr Clarke] explained that the reason for
disclosing the Helen Rose Report was its potential to
impugn Gareth Jenkins’ credibility as a witness and the
appendix did not speak to that issue."
Do you remember that?
Yes.
So can I now come, please, to POL00029707. This, you'll
remember, is an email that you write to Belinda Crowe --
Belinda Cortes-Martin -- as is now, and could we scroll
up to a paragraph which has contained within it - yes,
see that paragraph:
"Just for background information, the material part
of the Helen Rose Report has nothing to do with her
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comments about reversal data."
Then I omit words:
"The concern was not with the data's accuracy but
that the presentation of the data could be misleading if
its limitation were not fully understood. Putting this
issue aside, the real (and confidential) reason that the
report was disclosed was because Helen's comment at the
bottom of page 3 suggests that it was widely known that
there were problems with Horizon. This statement
(regardless of whether it is correct) could have been
used to attack Gareth Jenkins' credibility as
[a] Horizon expert as he had previously stated that
there were no problems with Horizon."
Now, I've already referred you back to the general
review by Mr Altman, where he said, at the page
reference I've given, quotation:
"The Helen Rose Report adds very little [or at least
so it seemed to him] other than to point to a particular
issue at Lepton and the implication from the report is
that, as early as February 2013, Gareth Jenkins was
aware of integrity issues with Horizon, none of which he
revealed."
Can I ask you this: did Mr Altman tell you that the
real and confidential reason for disclosure was that it
might permit an elliptical attack on Gareth Jenkins’
93
the Gareth Jenkins document.
Right. So I want to go now to one of the documents that
you refer to in footnotes, which is WBON0000834. This
what he's saying to you:
"This is the first I've seen of an appendix so it
did not go out with the disclosure pack. Nevertheless
my opinion (and) advice is unchanged. This was a data
presentation issue, not a Horizon failure -- see last
question and answer and a recommend in main report.
Thus the disclosure issue remains that relating to the
credibility of [Gareth Jenkins] as a witness only. I do
not see that the appendix is disclosable in the criminal
arena: it adds nothing to the credibility issue [of
Gareth Jenkins] and cannot therefore meet the test for
disclosure. Hope this helps.”
So it follows from that, out of his own mouth, that
Mr Clarke knew the reason to disclose was that it
revealed the Gareth Jenkins credibility issue?
Correct.
Not just the problems with Horizon that need to be
disclosed about bugs but also Mr Jenkins’ knowledge of
them and his failure to reveal them before ordering
trials: in other words, the classic unsafe witness
point.
Correct, there was a credibility issue with Gareth
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credibility?
A. I can't recall if it was Brian Altman that had told me
that but I understood that was the concern with the
Helen Rose Report.
Q. That concern was a concern that was shared, it's
obvious, because Mr Altman has written what he's
written, but it's a concern, you say, that is shared
among the criminal lawyers.
A. Yes.
Q. Right. So, in other words, the widely known problems
with Horizon could therefore be used to attack his
credibility because he'd stated previously, Mr Jenkins,
that there were none. Correct?
A. Yes, as I described it there, page 3 suggests there were
widely known problems.
Q. Right. Now Simon Clarke, Mr Clarke, based on your
statement, he thought that credibility was the real
reason to disclose, didn't he?
A. I believe that was the case. I can't --
Q. You checked it with him the day after your email of
8 April. On 9 April, you footnoted -- in fact, you
footnote 127 and 128 of paragraph 183. They are your
email to him about it, and his email to you.
A. Yeah, I recall around this time I spoke to Simon about
these issues and the redactions that had been made in
94
Jenkins’ evidence.
Q. Right, and it seems that Mr Altman appreciated the same
point, given what I've taken you to from his general
review?
A. Agreed.
Q. But it seems -- and you of course, as an intelligent
observer, apprised of the issues, it seemed that neither
of them were going the whole hog, as it were, neither
were following the logic inevitably demanded -- that
logic inevitably demanded that character and credit is
indivisible and Mr Jenkins' failure to disclose the
existence of bugs was inseparable from his failure to
act in accordance with his duties as an expert. You
must have realised this?
‘A. I was aware of those issues, yes.
Q. Did it not strike you as extraordinary that these two
experienced criminal lawyers were, as it were, dancing
around the elephant in the room?
A. It didn't at the time, no.
‘SIR WYN WILLIAMS: I Is that it, Mr Henry?
MR HENRY: I think that is it, sir.
‘SIR WYN WILLIAMS: = Thank you.
Ms Dobbin?
Questioned by MS DOBBIN
MS DOBBIN: Thank you, sir. Mr Parsons, can you see me?
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The Post Office Horizon IT Inquiry
Yes, I can.
I represent Gareth Jenkins, my name is Clair Dobbin.
I wanted to ask you about two things, if I may, and
the first thing is something, in fact, that my learned
friend, Mr Henry, has already touched upon. So I'm not
going to go back to this document but you'll recollect,
at the outset, he took you to an email of the 1 July
2013, that you wrote. Do you recollect that?
No, I'm afraid -- would you mind putting it up? Sorry.
Of course I will. It's WBON0000746.
Thank you.
So I think we can see, can't we, from this email,
Mr Parsons, that some work had been undertaken by your
firm, I think they had prepared some notes of the trial
of Mrs Seema Misra; is that correct?
Yes, but specifically targeting one question, which is
whether there was something in the transcripts that
referred to specific bugs in Horizon.
Yes. You had reviewed those notes and, as you've set
‘out there, you couldn't see anything that looked like
the 14 bug, the 62 bug, or the Falkirk bug, correct?
That's what it says there but, as I accepted earlier,
that was wrong because I think it does refer to the
Falkirk bug.
Yes, quite so. In fact, I think Mr Jenkins and a number
97
you recollect that?
That's -- that's my understanding.
I just wanted to ask you about this 62 bug, which
Mr Henry has also touched upon. I wanted to ask you
this: at the time you were speaking to Post Office about
this, did anyone mention to you or explain that
Mr Wilson, one of the prosecutors of Post Office, had,
in fact, made a decision that notes relating to that bug
shouldn't be disclosed to Mrs Misra at her trial?
I don't believe anybody told me that.
Did you ever speak at all -- again when you were doing
this work for Post Office and asking questions or trying
to ascertain what had been known at this time -- did you
ever speak to Mr Singh about what he knew, given the
role -- or given that he was the prosecutor, in fact, in
a number of cases?
I don't recall when I first spoke to Mr Singh. It may
have been after this. I don't recall asking Mr Singh
any questions about his state of knowledge.
Did he ever volunteer any information to you about what,
in fact, Mr Jenkins -- or information that Mr Jenkins
had provided to him in the course of Mrs Seema Misra's
trial -
I don't believe --
-- or the proceedings?
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of questions, didn't he, about the Callendar Square bug?
I can't recall now. I haven't looked at those memos for
along time.
Allright. But have you actually been through the
transcripts of the Misra trial?
No, I'll have only read the memo that was provided by my
team.
Right. So to be clear about this, this email of 1 July
is based upon a misreading of the memos that were
prepared for you; is that right?
Correct.
And you have never gone back and examined the
transcripts of the trial of Mrs Seema Misra?
I don't believe I've ever read the transcripts of Seema
Misra's trial.
Right. Well, Mr Parsons, I won't you any questions,
then, about those transcripts.
But then, just in terms of the other bugs, I think
it's right, isn't it, the 14 bug, I think you probably
now know, after the civil proceedings, that's a bug that
came to light at a later point, correct, the suspense
account bug?
Yes, this would have been around -- this is around
2011/2012, I think.
Yes, and I think came to Fujitsu's notice in 2013. Do
98
I don't believe so.
Another question that I wanted to ask you, related to
this, is that the Inquiry has seen evidence that, in and
around September 2013, a lawyer from Cartwright King and
a lawyer from the Post Office appeared to understand
that there was a serious issue as to whether or not
Mr Jenkins had ever been instructed as an expert.
Again, was that information that was ever brought to
your attention at the time by them?
I only first heard of that issue in the course of this
Inquiry.
It appears that your firm had recommended the
instruction of leading counsel in relation to the review
of the prosecutions because there was the concern that
there might be a conflict with Cartwright King; is that
correct?
I recall there being a concern over the conflict with
Cartwright King.
Do you think, then, that it was -- ought that
information, information that they knew in 2013, that
there was a serious issue as to whether or not
Mr Jenkins had been instructed as an expert, ought that
information not have been brought to your attention,
given the reason or the rationale for the instruction of
leading counsel?
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I think it's important to understand the nature of my
firm's role --
Yes.
-- which was to act, as I said yesterday, as a conduit
to Brian Altman. The scope of information that
Mr Altman then needed to do his job was left to
Mr Altman to inform us, actually, as to what information
he needed.
Yes. That's information that would be difficult for
Mr Altman to know, that information, unless someone
volunteered it to him. Correct?
I guess so, though I wonder whether, if Mr Altman had
asked certain questions, that information would have
been brought to light.
All right, Mr Parsons, this isn't a criticism of you;
I'm just trying to understand, given your concerns or
your firm's concerns, about potential conflict related
to Cartwright King's conduct of prosecutions and their
understanding that there was a serious question as to
whether Mr Jenkins had been instructed as an expert,
again, whether you think that that is information that
‘ought to have been brought to your attention at the
time?
Looking back now, it seems like it's information that
should have been but I'm very cautious about the phrase
101
related to the civil proceedings.
I'm not going to go back to your witness statement,
Mr Parsons, to cover this. I wanted to see if I could
just do it without having to do that. I think that you
suggest that there was the concern about using
Mr Jenkins as a source of information in the civil
proceedings, correct?
There was a concern about using him as a witness in the
proceedings and, related to that, there was then doubts
over the information that we were getting from Gareth
Jenkins, but we still, nevertheless, spoke to him and
sought his opinion on certain points.
All right. I wanted to ask you this: can you point us
to any communications, for example, emails or written
correspondence, with Fujitsu in which you set out any
direction or instruction about the approach that they
were to take to Mr Jenkins, or the use that was to be
made of Mr Jenkins in providing information in the civil
proceedings?
I can't recall any such email at the moment.
Was there such an email, Mr Parsons?
The best of my recollection is no but there was,
obviously, a lot of correspondence around that time so
I couldn't state definitively.
Right. So is it the position, Mr Parsons, that, despite
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“brought to my attention" because, as I say, we were —-
our role was to make sure the information was flowed
through to Brian Altman and for Brian to make requests
for what information he needed.
Well, let me broaden it out, then. It's right, isn't
it, that that is information that ought to have been
brought to Mr Altman's attention at that time?
It strikes me that that's -- that would be useful
information for Mr Altman to have known.
Yes, it's useful because, I think -- to use Mr Henry's
turn of phrase -- it would have opened up questions,
wouldn't it, about Post Office's management, to use his
term, of Mr Jenkins -- correct --
Yes, I can see that line of inquiry.
-- and may, indeed, have opened up wider questions as to
Post Office's ability to conduct prosecutions as well;
do you agree?
I'm not sure I am able to answer that second question as
to what Post Office might do with future prosecutions.
Sorry, it was badly put by me. It might open up
questions as to the competency with which Post Office
had been prosecuting cases; do you agree?
Yes, if Mr Jenkins had been improperly instructed.
Yes, all right. I'm going to be move on and ask you
about a completely separate topic, if I may, and that's
102
this concern or caution around using Mr Jenkins, that
was not, in fact, something that was communicated to
Fujitsu?
It - I don't -- it wasn't communicated by me to
Fujitsu. I don't know if somebody else had communicated
it from Post Office to Fujitsu. But I was operating on
the understanding that Fujitsu were unaware of the
concerns we had about Gareth Jenkins’ evidence.
I was just looking at the transcript because I wanted to
make sure I hadn't misheard you. Fujitsu were unaware
of the concerns about Mr Jenkins’ evidence; is that
correct?
I'm saying that was my understanding at the time.
Yes. You are the key person, Mr Parsons, aren't you, in
terms of the conduct of the civil litigation?
Yes, I think that's fair, alongside leading counsel.
Yes, and it follows from all of that, doesn't it,
Mr Parsons, that Mr Jenkins didn't know the position
that he was being put in in the civil litigation either?
I can't talk to Mr Jenkins' state of knowledge.
Well, he didn't know, did he, because you didn't
communicate it to Fujitsu, that he wasn't being used as.
a witness because of these historic concerns about the
evidence that he had given previously or the criticisms
that had been made of him?
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A. I think -- as I say, I can't speak to Gareth Jenkins’
knowledge but, as far as I was aware, he was not aware,
if I can put it that way.
Q. Can I just ask: how could you have let that situation
arise, Mr Parsons, whereby you were making use of
someone as a source of information in the civil
proceedings and yet, all the while, not telling them
that they had been subject to this previous criticism
and, in fact, that was the reason why they weren't being
used as a witness?
A. So, as I explained in my statement, it was a less than
ideal situation. In fact, it was a very difficult
situation. Our expectation, until much later in the
Group Litigation, is that we wouldn't need to rely on
Gareth Jenkins. We thought we'd be able to get the
evidence from Torstein Godeseth or some others at
Fujitsu. I was aware there was always a concern that
there would be points on which only Gareth may be able
to give evidence, but until the issues in the litigation
took shape, around the Horizon issues, that is, that
only really took shape around, I think it was, August
‘18, so quite deep into the litigation, the point around
Gareth Jenkins’ role and his role as a witness hadn't
taken -- hadn't really taken hold until that point in
time.
105
Office to manage in the litigation process but I -- that
idea did not cross my mind whilst we were in the
litigation.
MS DOBBIN: Yes. Thank you, Mr Parsons.
‘SIR WYN WILLIAMS: I Is that it, Mr Blake?
MR BLAKE: I believe thatis, sir. Yes.
‘SIR WYN WILLIAMS: All right.
Well, thank you very much, Mr Parsons, for your very
detailed witness statement and for answering questions
posed to you by a number of people over a day and a half
at this Inquiry. I'm grateful to you.
So we'll stop now and adjourn until Tuesday morning,
when we'll hear from Mr Henderson, I believe.
MR BLAKE: That's correct, sir.
‘SIR WYN WILLIAMS: All right. Thank you all very much.
MR BLAKE: Thank you very much.
(12.56 pm)
(The hearing adjourned until 9.45 am
on Tuesday 18 June 2024)
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But do you see the position that you were putting him in
but without him knowing anything about the reality of
his situation?
I think we were speaking to Gareth as a source of
information and, given that we had decided not to call
him as a witness, I didn't see there was a challenge
with that.
But you didn't see that you were potentially exposing
him or putting him in a difficult position by doing
that, given, for example, you know, whenever witnesses
said that they had spoken to him about something,
whenever they came to give evidence, can you not see
that that's putting someone in a difficult position?
I'm not sure what difficulties you are envisaging here.
We were asking Gareth questions, he was, I'm sure to the
best of his availability answering those questions.
I don't see asking someone questions and getting answers
puts them in a spot of difficulty.
You don't see a difficulty in using someone in
litigation, in making a decision not to call them as
a witness, in deciding that you need to be very cautious
and careful about how you're using them, and yet not
tell that person that that's the position they're in;
you don't see a problem with that?
There's several difficulties but they're mainly for Post
106
ANDREW PAUL PARSONS (continued) 1
Questioned by MR BLAKE (continued) ... 1
Questioned by MR JACOBS ... 35
Questioned by MR HENRY .. 50
Questioned by MS DOBBIN .. 96
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50/12 55/23 60/13
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MR JACOBS: [5]
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44/23 50/1
MR MOLONEY: [1]
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MS DOBBIN: [2]
96/25 107/4
SIR WYN WILLIAMS:
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33/11 33/15 33/22
34/1 34/6 34/8 34/12
34/21 35/3 35/9 35/13
44/19 50/5 55/21
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15 [3] 34/24 72/24
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150 [2] 48/22 52/25
156 [1] 35/15
157 [1] 48/3
17 July [2] 53/22
80/23
17 June [1] 37/11
172 [1] 17/15
18 June 2024 [1]
107/19
183 [3] 92/8 92/11
94/22
19 [2] 79/17 83/21
19 October [1] 11/1
"48 [1] 105/22
49 [1] 14/24
‘cultural [1] 31/10
‘damned [1] 60/2
‘Misra’ [1] 79/22
‘normally’ [1] 28/15
‘Old [1] 59/18
‘productive’ [1]
14/24
‘whitewash’ [1] 60/4
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1 January [2] 27/14
27/22
4 July [3] 77/25 97/7
98/8
4 May [4] 65/2
1 November [1]
13/17
4.40 [1] 74/23
1.45 [1] 74/23
10 [1] 15/6
10.00 [1] 14/6
10.20 [1] 49/6
10.34 [1] 35/6
10.45 [1] 33/15
10.50 [2] 34/24 35/8
44 May [4] 25/12
11 September [2]
6/23 10/24
11.20 [4] 74/17
11.50 [1] 74/25
110 [1] 92/12
110 million [1] 19/21
2
20 [1] 79/19
2004 [4] 2/7
2010 [5] 27/14 27/22
28/2 59/22 90/20
2011/2012 [1] 98/24
2012 [2] 61/5 98/24
2013 [16] 26/20 43/1
44/1 51/9 53/4 61/25
62/9 62/14 76/5 80/23
88/11 93/20 97/8
98/25 100/4 100/20
2014 [3] 37/11 43/21
88/19
2015 [2] 35/23 85/19
2015/2016 [1] 66/3
2016 [5] 18/9 18/17
64/13 65/2 66/3
2017 [3] 6/23 10/24
11/1
2018 [6] 2/1 13/17
17/23 19/2 19/5 25/16
2019 [1] 13/23
2024 [3] 1/1 43/18
107/19
204 [2] 8/18 8/19
21 October [1] 88/25
22 October [1] 2/1
23 March [1] 19/5
24 [1] 72/23
253.3 [1] 45/1
26 August [1] 88/11
3
3.00 [1] 45/20
30 [1] 79/20
32 [4] 79/20
357 [2] 8/20 8/20
358 [2] 8/20 9/22
359 [1] 8/20
3rd [2] 14/18 15/12
4
4.2 [4] 11/19
4.3 [1] 12/8
433 [1] 23/21
4A [1] 79/4
5
5 October [1] 88/16
500 [1] 12/6
522 [1] 11/20
53 [1] 38/7
54 [1] 92/3
6
6 December [1]
14/14
62 [4] 77/21 79/18
97/21 99/3
8
8 April [1] 94/21
8 July [2] 53/22
80/22
8 October [1] 62/13
855 [2] 29/5 29/6
856 [1] 28/24
87 [1] 80/21
9 April [1] 94/21
9 September [4]
26/20 53/3 62/9 76/5
9.45 [2] 1/2 107/18
A
abandon [1] 12/10
ability [3] 20/14
21/13 102/16
able [14] 2/13 18/12
21/9 21/15 22/6 26/22
27/1 29/2 36/11 55/16
59/17 102/18 105/15
105/18
about [120]
above [5] 9/23 24/25
67/11 71/25 72/3
absolute [2] 49/8
49/9
absolutely [2] 3/4
33/14
accept [11] 17/24
36/11 36/13 45/12
47/19 48/9 52/16
52/22 53/16 61/25
83/3
acceptable [1] 48/11
accepted [7] 55/21
63/10 68/6 73/17
73/18 83/13 97/22
access [8] 40/19
60/7 60/9 64/20 66/4
68/3 90/18 90/20
accommodate [1]
15/22
accordance [3]
73/22 83/19 96/13
account [3] 5/25
61/16 98/22
accountable [2]
22/12 24/11
accounting [5] 22/11
24/10 60/7 61/4 80/8
accumulate [1] 65/13}
accuracy [1] 93/3
accused's [1] 86/14
accusing [1] 40/20
achieve [2] 16/1
59/16
across [2] 31/9 34/9
act [5] 75/6 75/12
81/18 96/13 101/4
acted [2] 69/15 83/19
acting [4] 28/13
40/17 49/14 50/21
action [4] 10/4 10/8
46/23 51/22
actions [4] 24/12
32/4 49/2 59/10
actual [2] 31/4 76/12
actually [16] 12/25
16/24 18/3 29/6 40/21
48/14 56/1 61/12 68/6
68/13 69/6 69/21
84/15 84/16 98/4
101/7
adamant [1] 5/1
add [1] 35/2
added [4] 28/5 29/12
29/13 29/16
address [2] 11/20
59/17
addressed [3] 8/16
23/20 39/11
adds [2] 93/17 95/13
adjourn [1] 107/12
adjourned [1] 107/18
administrative [1]
24/18
admittedly [1] 85/19
adopt [3] 9/14 9/15
12/19
adopted [1] 11/9
advance [2] 36/22
54/4
advantage [2] 14/21
48/18
advantages [2] 10/4
16/18
adversarial [3] 9/10
9/17 48/17
advice [53] 16/14
16/24 17/2 17/22
17/24 22/20 22/22
26/14 26/15 26/18
28/8 30/5 30/6 30/25
31/14 31/15 38/20
40/2 41/12 42/8 42/14)
42/22 43/2 43/6 49/19)
49/19 53/20 53/22
54/7 69/25 70/19
71/20 72/18 75/16
76/19 80/23 81/17
81/23 81/25 82/7
82/10 82/15 82/19
84/2 84/7 84/7 84/20
84/20 85/4 85/18
89/25 90/3 95/7
advise [2] 10/1 58/4
advised [11] 10/18
16/7 21/7 28/1 28/9
41/10 43/19 46/9
46/10 66/14 81/15
advising [11] 16/8
30/1 32/12 39/7 39/19I
40/4 43/12 54/5 76/2
76/5 79/7
advisory [1] 31/25
advocate [1] 10/5
advocating [4] 8/15
12/23 13/4 13/14
affect [1] 30/19
affected [1] 63/19
afraid [6] 5/1 18/15
21/11 21/17 53/11
97/9
after [12] 18/4 19/3
21/13 23/15 35/23
62/13 65/12 81/12
88/2 94/20 98/20
99/18
afternoon [1] 45/21
again [18] 5/21 11/25
30/18 38/20 39/23
41/15 44/16 49/14
58/9 62/18 73/16
74/22 82/10 85/4
89/14 99/11 100/8
101/21
against [7] 46/24
47/3 48/18 80/13
82/11 82/24 90/25
aghast [1] 49/2
ago [4] 2/10 47/18
53/11 53/13
agree [7] 16/4 16/10
16/11 24/19 59/22
102/17 102/22
agreed [6] 27/2 33/6
46/23 76/17 85/14
96/5
agreeing [2] 8/13
23/24
agreement [2] 20/8
(28) MR BLAKE: - agreement
A
agreement... [1] 47/6
ah [1] 33/25
aimed [1] 67/21
airbrushed [1] 85/9
Alan [3] 48/2 48/15
64/18
alerted [1] 81/23
Alex [3] 22/11 24/10
25/5
Alice [1] 89/4
alive [1] 68/22
all [56] 3/18 11/18
12/15 13/21 14/10
26/20 27/17 27/25
29/2 31/21 32/2 33/1
34/12 34/22 43/16
46/1 46/4 50/13 51/20
57/17 57/17 57/23
58/16 58/17 59/9 60/7
61/21 61/23 65/5
68/13 69/4 69/13
71/22 73/16 75/25
77/17 80/11 80/17
82/22 82/25 83/3 85/6
85/6 85/22 89/15 90/2
98/4 99/11 101/15
102/24 103/13 104/17)
105/7 107/7 107/15
107/15
Allen [1] 4/22
allow [1] 51/16
almost [2] 61/17
63/22
along [4] 36/17 49/15
51/1 67/11
alongside [2] 75/7
104/16
already [13] 5/5 20/9
28/11 47/25 52/6
56/24 63/8 76/17
76/24 80/20 90/4
93/14 97/5
also [24] 1/13 2/24
3/8 8/8 8/11 13/12
14/8 15/23 28/6 28/23}
28/25 30/7 43/9 61/14,
70/10 70/19 70/22
77/9 79/7 90/8 90/17
90/18 95/21 99/4
alternative [2] 5/16
5/20
although [4] 7/25
33/8 70/23 88/4
Altman [38] 26/18
27/8 27/9 28/1 28/9
30/1 30/6 30/7 54/2
58/8 66/14 70/11
70/13 70/18 71/9 73/2
74/1 75/25 81/16
82/22 83/22 84/3
84/19 85/13 91/24
92/4 93/15 93/23 94/2
94/6 96/2 101/5 101/6
101/7 101/10 101/12
102/3 102/9
Altman's [8] 28/8
70/15 72/20 83/23
84/21 85/18 89/12
102/7
always [10] 10/7
13/14 21/5 46/20
47/10 61/8 63/16
64/12 89/20 105/17
am [13] 1/2 4/5 5/1
25/3 35/6 35/8 36/21
41/19 42/7 74/25
75/24 102/18 107/18
ambit [1] 71/2
amendment [1]
88/11
amendments [4]
1/14 87/22 88/2 88/13
among [1] 94/8
amongst [6] 8/7
16/12 16/25 17/5
17/12 18/1
amounted [1] 45/9
Amy [2] 19/4 19/6
ANDREW [3] 1/3 3/1
107/20
Andy [7] 5/24 19/14
25/2 25/15 41/18
66/12 89/6
Angela [1] 37/12
Anne [1] 6/15
anodyne [1] 68/24
Anomalies [1] 79/18
Anomaly [1] 79/21
another [14] 2/21 4/7
5/8 10/23 18/6 28/7
44/4 51/10 60/12
74/13 74/16 75/15
89/6 100/2
answer [2] 95/9
102/18
answering [2] 106/16
107/9
answers [1] 106/17
anticipating [1] 12/4
ation [1] 54/1
any [58] 4/10 4/12
6/12 6/17 6/18 9/2 9/5
9/18 16/21 18/14
18/18 21/9 24/17 25/9)
25/16 26/4 31/8 32/3
32/4 32/11 32/19
32/20 32/21 32/24
34/12 38/23 45/23
46/23 49/1 50/1 50/4
50/13 52/8 52/8 53/9
55/16 59/17 63/4 65/7
65/11 68/8 69/21
70/13 73/12 77/2
78/13 79/13 79/14
81/20 84/22 85/5
89/22 98/16 99/19
99/20 103/14 103/15
103/20
anybody [4] 75/23
80/14 80/14 99/10
anyone [1] 99/6
anything [17] 4/13
4/18 6/6 21/20 38/18
48/12 49/18 67/12
68/16 75/25 76/2
77/14 77/21 78/15
88/21 97/20 106/2
anywhere [1] 16/23
apart [1] 24/2
apologise [6] 34/9
36/17 49/14 49/16
49/25 57/14
apologised [3] 45/22
49/13 49/16
apology [1] 49/1
apparent [1] 19/3
apparently [1] 87/7
appeal [13] 15/23
28/16 73/21 76/8
88/10 88/14 90/7 90/7
90/10 90/11 90/13
90/25 90/25
appeals [3] 69/9
80/12 90/17
appear [4] 2/9 2/20
3/5 77/22
appearance [2] 4/4
4113
appearances [1]
69/4
appeared [3] 17/18
88/4 100/5
appears [6] 6/9 20/19}
21/12 86/1 87/21
100/12
appellant [1] 69/12
appendix [3] 92/16
95/5 95/12
applicants [1] 38/15
applied [2] 41/4
50/16
applying [5] 9/3 9/7
9/9 10/1 10/21
appoint [1] 20/3
appointed [2] 18/22
83/21
appointment [3]
20/10 22/2 59/8
appreciate [2] 14/3
33/9
appreciated [1] 96/2
apprised [1] 96/7
approach [16] 9/1
9/2 9/3 13/6 13/7
19/16 29/25 38/22
40/13 40/14 41/19
43/16 45/9 51/3 51/4
103/16
approached [2] 28/3
59/2
approaches [2] 10/1
10/3
appropriate [2] 34/14
46/14
approval [1] 27/7
April [2] 94/21 94/21
Arbuthnot [4] 79/13
architect [1] 85/7
archived [1] 30/21
are [69] 2/3 4/1 4/24
7/18 7/22 8/7 9/10
11/17 12/11 12/12
12/25 15/19 15/24
19/16 20/6 20/20 21/8}
24/2 24/3 24/9 26/19
26/22 27/1 27/18
28/21 29/2 33/1 35/9
35/15 35/16 35/17
35/18 36/2 36/11
40/20 45/23 46/20
50/19 53/5 54/18 56/8)
56/9 56/9 57/10 60/3
60/3 60/5 60/8 60/18
60/18 61/20 66/11
67/14 68/17 68/20
75/3 75/13 75/19
81/23 83/13 83/13
83/15 84/6 84/15
84/25 89/21 94/22
104/14 106/14
aren't [2] 83/14
104/14
arena [1] 95/13
arguable [1] 36/20
arguments [1] 45/19
arise [1] 105/5
arising [1] 20/21
arose [1] 10/6
around [22] 13/8
15/17 17/5 18/4 21/1
21/5 26/12 26/15
29/20 30/5 44/2 66/3
94/24 96/18 98/23
98/23 100/4 103/23
104/1 105/20 105/21
105/22
arrangement [1] 47/5]
arrangements [2]
22/25 32/1
arranging [1] 53/14
arrogance [1] 49/8
as [176]
ascertain [1] 99/13
aside [2] 14/4 93/6
ask [16] 1/23 3/24
34/15 35/14 50/2 58/7
66/17 72/15 93/23
97/3 99/3 99/4 100/2
102/24 103/13 105/4
asked [12] 3/9 18/12
35/21 35/24 42/25
55/15 62/7 65/5 70/7
72/22 78/13 101/13
asking [6] 1/21 50/19
99/12 99/18 106/15
106/17
asks [1] 25/6
asserted [2] 79/23
80/3
assertion [1] 42/1
assessed [1] 46/8
assessment [2]
12/20 71/21
assiduous [1] 56/9
assist [9] 2/14 19/5
21/9 21/15 26/22 27/1
29/2 31/16 72/5
assisted [1] 86/14
assisting [1] 2/17
associate [6] 55/13
56/6 56/17 64/24 65/1
78/3
assume [2] 15/3 90/1
astute [1] 70/10
at [179]
attach [1] 2/24
attached [5] 2/7 2/19
2/21 3/22 15/21
Attaches [1] 77/15
attack [3] 93/11
93/25 94/11
attacking [2] 35/25
38/17
attempt [3] 52/3
68/24 69/8
attend [3] 44/11
46/12 46/14
attended [3] 18/16
35/17 46/3
attendees [1] 18/23
attending [1] 44/12
attention [7] 6/17
38/19 100/9 100/23
101/22 102/1 102/7
attitude [1] 14/11
attrition [5] 7/3 8/7
8/23 10/15 12/24
audience [1] 12/18
audit [2] 27/16 27/24
August [2] 88/11
105/21
Aujard [3] 37/12 59/1
59/7
author [3] 11/11
31/17 81/7
authority [1] 46/6
auto [1] 39/21
availability [1]
106/16
avert [1] 51/21
avoid [1] 7/23
aware [19] 5/6 6/12
20/25 25/22 45/8
53/21 59/5 59/6 60/21
75/24 80/20 81/20
89/18 91/25 93/21
96/15 105/2 105/2
105/17
(29) agreement... - aware
A
awareness [2] 76/23
76/25
away [2] 45/19 68/25
back [25] 5/4 5/25
16/22 18/2 20/23 36/5)
36/13 36/14 36/18
36/18 41/15 43/1
43/25 44/1 45/20 51/8)
53/3 56/2 81/14 88/12
93/14 97/6 98/12
101/24 103/2
background [3] 24/8
59/9 92/24
badly [2] 36/5 102/20
balanced [2] 27/17
27/25
bankrupted [1] 43/22
bar [1] 63/10
based [6] 13/4 39/5
78/11 91/22 94/16
98/9
basis [6] 23/8 23/8
41/22 46/22 47/20
62/4
Bates [3] 48/2 48/5
48/15
bay [3] 54/12 61/21
61/23
be [135]
bear [1] 34/22
became [2] 13/13
35/22
because [55] 6/9 8/7
8/24 12/3 18/2 20/18
25/24 26/9 27/3 32/14
40/5 40/17 42/17
45/13 52/6 53/18
54/10 56/6 56/23
59/11 64/9 65/19
68/11 69/20 70/2
71125 74/17 76/3
76/25 80/4 81/2 81/22
82/3 83/5 84/6 87/4
87/6 87/21 87/24
88/11 89/19 90/18
91/20 91/23 92/4 93/7
94/6 94/12 97/23
100/14 102/1 102/10
104/9 104/21 104/23
become [4] 6/2 7/12
7/20 61/6
bed [1] 31/8
Bedford [2] 53/6 53/8)
been [86] 9/4 10/9
12/15 13/19 18/22
27/3 28/18 29/12
29/18 31/5 31/10
31/11 32/17 34/24
36/9 39/6 40/23 41/2
A1I7 43/22 43/23 45/7
45/25 46/16 47/25
48/12 49/2 51/19 52/6
53/25 54/3 54/16
55/13 55/25 56/1
56/13 56/25 61/2 61/2
61/14 63/14 65/1 66/5
71/25 72/9 72/10 80/3
80/6 80/12 80/17
81/11 82/16 86/1
86/24 87/24 88/5
88/12 89/12 89/18
89/19 90/2 90/12
90/22 90/23 91/2 91/7,
91/11 93/10 94/25
97/13 98/4 98/23
99/13 99/18 100/7
100/22 100/23 101/14}
101/20 101/22 101/25)
102/6 102/22 102/23
104/25 105/8
before [17] 1/11 7/12
8/25 16/6 33/10 39/13
52/11 52/18 53/1 54/5
62/24 63/16 71/13
81/24 81/25 89/19
95/22
began [4] 15/16
15/16 51/8 61/25
begin [2] 1/21 33/10
beginning [3] 19/15
36/18 85/19
begins [3] 14/14 15/2
38/1
behalf [2] 35/15
36/22
behaving [1] 36/4
behind [2] 60/21
63/15
being [42] 3/12 4/1
6/4 6/16 8/3 16/24
16/25 17/5 17/25
19/20 20/13 22/6 22/7,
23/4 26/11 31/18
36/21 37/20 39/11
39/20 41/21 51/12
53/7 55/15 55/16 57/2
57/6 58/17 59/2 66/6
69/19 70/23 72/3
76/12 78/12 79/16
81/15 85/3 100/17
104/19 104/22 105/9
BEIS [1] 19/16
belief [1] 1/18
believe [37] 2/12
4/15 4/17 6/6 7/11
10/17 12/8 16/23
22/24 32/6 33/8 38/17
40/10 41/4 45/24 48/6
48/10 52/24 66/21
68/21 69/5 69/5 69/20
70/14 71/5 73/17
75/21 79/13 86/22
91/12 94/19 98/14
99/10 99/24 100/1
107/6 107/13
believed [6] 51/11
51/24 51/25 62/1 63/7
66/23
believes [1] 7/18
Belinda [4] 37/13
89/7 92/20 92/21
below [7] 12/17 13/3
14/1 14/9 19/15 43/14
64/16
bench [1] 15/4
benefit [2] 33/16
38/18
best [4] 1/17 15/23
103/22 106/16
better [1] 12/8
between [11] 6/17
17/1 22/25 33/6 34/14
38/3 38/14 42/10
46/15 52/16 54/15
beyond [3] 26/13
80/11 80/17
Big [1] 71/20
bigger [1] 13/13
Bill [4] 19/21
bit [2] 45/2 50/9
BLAKE [12] 1/4
33/18 34/25 36/10
41/10 49/4 62/20
69/24 76/18 89/3
107/5 108/3
blown [1] 90/18
blurting [1] 69/11
board [12] 18/21
19/25 20/2 20/4 20/15)
21/24 22/16 22/21
23/1 24/17 79/6 79/7
body [1] 67/7
Bogerd [1] 37/13
Bond [12] 2/12 2/22
3/2 3/6 9/25 21/25
22/4 46/5 61/24 64/22
70/23 73/1
both [5] 4/24 28/24
40/14 76/9 76/10
bottom [13] 1/25
5/14 22/10 22/14
25/11 27/11 29/7
29/10 31/6 78/19
78/19 78/23 93/8
bound [3] 58/1 58/11
77/3
Bourke [2] 25/11
64/13
Bowyer [1] 55/9
box [1] 40/16
brackets [1] 79/12
brain [3] 16/15 17/1
58/8
branch [3] 79/18
79/19 80/5
branches [2] 27/17
27/25
breach [3] 38/15
57/19 83/16
break [9] 33/9 34/14
34/17 34/18 34/23
35/7 50/6 74/19 75/1
breather [1] 50/9
Brian [28] 26/18 27/3
27/7 27/8 27/9 27/25
28/9 30/1 71/10 72/5
72/19 73/2 73/7 76/2
76/10 81/16 82/22
83/21 83/23 84/3
84/19 85/13 85/18
89/12 94/2 101/5
102/3 102/3
Brian's [2] 54/7
71/20
briefing [1] 18/21
briefly [2] 53/3 86/3
bring [5] 1/11 8/17
32/8 46/23 54/17
brink [1] 39/4
broaden [1] 102/5
brought [6] 100/8
100/23 101/14 101/22}
102/1 102/7
bug [17] 77/21 77/21
77/22 78/15 78/16
90/21 91/5 97/21
97/21 97/21 97/24
98/1 98/19 98/20
98/22 99/3 99/8
bugs [7] 63/9 78/4
78/13 95/21 96/12
97/18 98/18
built [2] 52/12 52/13
bullet [3] 8/11 59/12
59/24
bullets [1] 11/17
burden [2] 24/18
33/22
burdened [1] 33/20
buried [1] 85/22
burn [2] 15/25 16/9
burning [1] 15/11
bus [1] 36/8
business [6] 7/21 8/8)
18/10 18/17 18/19
31/9
busy [1] 14/3
but [134]
byproduct [3] 10/8
10/12 10/20
Cc
call [13] 10/14 14/6
19/4 19/15 20/19
21/12 25/15 25/16
25/18 43/5 82/3 106/5
106/20
Callard [1] 25/13
called [2] 2/2 6/4
Callendar [1] 98/1
calling [1] 36/1
came [9] 18/2 25/14
37/3 40/21 45/20
81/13 98/21 98/25
106/12
can [86] 1/5 1/6 1/15
1/20 3/23 4/10 5/10
5/13 6/20 7/1 7/18
8/17 14/8 14/17 15/22I
16/18 17/21 19/1 19/5)
19/9 19/10 23/18
26/21 27/11 27/18
27/20 28/7 29/1 29/5
29/11 29/14 30/12
31/5 31/16 33/13
33/13 33/17 33/19
34/2 34/15 35/9 35/11
35/13 37/8 44/16
44/21 46/15 47/24
50/6 53/7 54/22 60/9
62/16 64/19 64/25
66/7 66/15 66/25
67/19 73/3 73/12 74/1
74/13 74/23 77/24
77125 78/18 78/19
79/11 81/22 84/11
85/10 86/5 86/11
86/20 87/18 92/19
93/23 96/25 97/1
97/12 102/14 103/13
105/3 105/4 106/12
can't [33] 3/16 3/20
4/12 14/7 25/18 29/24)
31/17 32/9 32/18
32/21 32/21 42/12
53/8 53/11 55/6 63/24
66/1 72/8 72/10 76/4
76/16 77/20 78/14
79/2 81/4 90/10 94/2
94/19 97/12 98/2
103/20 104/20 105/1
candid [1] 73/22
cannot [2] 24/18
95/14
canvassed [1] 52/6
capacity [1] 23/5
cards [1] 88/11
care [1] 29/18
careful [4] 67/12
68/10 68/15 106/22
careless [1] 69/10
Cartwright [24] 30/7
37/18 38/16 39/12
40/3 40/11 43/12
43/15 72/20 72/22
75/22 76/9 81/16
84/18 85/11 87/23
88/2 88/10 88/13
88/16 100/4 100/15
100/18 101/18
case [42] 2/14 3/3
3/4 7/18 8/14 11/1
11/17 11/22 12/3
12/17 13/3 28/4 33/2
33/24 36/20 36/22
41/22 41/22 44/10
(30) awareness - case
Cc
case... [23] 46/8
47/13 56/6 57/24 58/9)
68/12 69/19 77/12
77/23 78/1 80/1 86/1
86/13 86/18 86/19
86/25 87/1 87/3 87/17
88/6 88/6 88/7 94/19
case-specific [1]
28/4
cases [32] 16/4 16/4
21/19 28/10 32/11
32/14 37/22 46/9
46/19 46/25 48/23
48/23 52/9 52/15
52/25 53/1 54/12
59/18 59/20 59/22
60/8 68/25 69/1 69/2
70/3 82/9 83/18 84/15
85/12 88/23 99/16
102/22
cash [2] 27/16 27/24
cast [1] 42/1
catastrophic [1]
90/23
cause [2] 52/15
79/24
caused [6] 19/22
23/16 49/19 68/2 69/9
91/3
causes [2] 22/17
68/12
causing [2] 10/17
64/2
caution [3] 28/9 30/2
104/1
cautious [2] 101/25
106/21
CCRC [11] 21/13
32/23 72/6 82/16
82/25 83/8 84/23
85/16 85/16 85/19
89/24
centrally [1] 30/21
certain [7] 12/17 13/3}
26/18 87/16 88/9
101/13 103/12
Certainly [2] 74/21
74/21
cetera [6] 16/5 31/13
68/5 68/5 78/9 78/9
chain [3] 25/9 25/10
41/15
Chairman [2] 54/18
74/3
challenge [2] 40/18
106/6
Challenges [1] 14/25
Challenges/factors
[1] 14/25
chambers [2] 6/15
53/8
chance [2] 78/22
81/1
change [1] 13/5
changed [1] 27/21
changes [1] 28/20
chapter [1] 86/7
character [1] 96/10
characterisation [1]
42/24
characterise [1] 51/7
charges [1] 80/10
chatter [1] 8/1
cheaply [1] 51/21
checked [2] 2/8
94/20
Chisholm [3] 22/11
24/10 25/5
choices [2] 43/8
81/21
chosen [1] 5/12
Chris [8] 2/2 4/22
4/22 4/23 37/12 59/1
59/7 64/20
circulate [1] 72/14
circumstance [1]
61/3
circumstances [8]
11/22 41/20 41/23
42/2 42/5 42/9 42/11
57/18
civil [21] 32/6 40/15
54/12 54/17 59/17
60/8 62/10 73/4 73/10
73/13 74/2 74/4 74/7
74/9 98/20 103/1
103/6 103/18 104/15
104/19 105/6
civil/criminal [1]
59/17
claimants [15] 2/3
2/12 6/20 7/6 7/12
8/25 9/4 9/6 10/21
12/9 12/21 14/22 15/4
15/25 16/9
claimants' [7] 2/5
7/15 8/13 10/2 13/10
15/7 15/10
claims [14] 11/18
11/21 12/6 12/10
12/11 47/3 47/6 47/8
54/17 60/6 60/24
62/10 63/13 63/20
Clair [4] 97/2
clarify [1] 66/18
Clarke [23] 31/10
31/14 42/14 42/22
43/2 53/20 53/22 55/9)
80/23 81/23 81/25
82/15 84/2 84/7 84/7
84/16 89/25 90/3 92/9)
92/13 94/16 94/16
95/17
Clarke's [2] 30/9
30/25
class [1] 51/22
classic [1] 95/23
clear [13] 2/19 3/3
3/6 8/6 8/23 38/4
43/14 49/14 50/17
63/1 87/24 92/11 98/8
clearer [1] 88/5
clearly [6] 39/3 40/13
71/12 80/4 82/16
88/10
client [12] 9/24 16/24
17/2 35/22 35/24 36/4
36/23 37/2 38/21
42/21 43/12 51/5
clients [11] 35/17
45/14 45/15 46/3
46/17 46/20 49/2 49/5
49/17 49/20 67/22
cloaked [1] 82/15
close [5] 27/15 27/23
35/22 67/18 69/8
closing [1] 69/22
CMC [1] 11/6
Co [8] 35/16 37/19
37/24 38/13 39/4 40/6
40/23 41/1
coalescing [1] 53/18
cold [1] 12/19
collapse [1] 73/23
colleague [2] 2/21
4/3
collective [1] 12/9
column [1] 8/12
combined [1] 43/16
come [14] 1/20 5/4
21/10 25/13 37/10
41/25 44/17 48/8
54/21 56/22 58/22
84/16 86/3 92/19
comes [2] 48/1 63/24
comfortable [1]
67/16
coming [2] 30/6
30/16
comment [11] 15/19
25/24 29/23 29/24
50/19 71/19 73/9
73/11 73/15 90/10
93/7
commentary [1] 2/24
commented [1] 2/18
comments [6] 25/10
67/14 67/20 68/17
68/20 93/1
commercial [1] 9/20
Commission [1]
21/20
Committee [1] 22/16
Common [4] 13/24
14/13 17/13 90/16
communicate [1]
104/22
communicated [3]
104/2 104/4 104/5
communications [1]
103/14
company [2] 3/17
20/9
comparison [1] 86/3
compensation [2]
19/21 60/24
competency [1]
102/21
complaints [1] 52/3
complete [1] 52/20
completely [1]
102/25
comprehensive [1]
24/13
computer [2] 30/18
55/25
concede [1] 63/3
conceded [1] 63/23
concentrate [1]
54/21
concern [21] 20/13
21/4 21/18 23/2 28/12,
38/1 38/2 64/1 87/13
91/4 93/3 94/3 94/5
94/5 94/7 100/14
100/17 103/5 103/8
104/1 105/17
concerned [10] 3/12
21/5 25/3 39/4 40/6
64/5 70/2 84/1 84/6
84/15
concerns [21] 3/25
6/3 6/7 6/18 22/2 23/9)
23/11 23/13 23/17
26/7 40/9 61/14 61/15
62/9 64/4 65/16
101/16 101/17 104/8
104/11 104/23
concluded [1] 62/2
conclusion [3] 11/22
12/3 14/20
conditional [1] 12/13
conduct [6] 18/12
44/4 57/19 101/18
102/16 104/15
conducted [1] 47/20
conduit [1] 101/4
conference [5] 11/2
14/6 26/20 55/16
55/17
confidential [3]
65/10 93/6 93/24
confidentiality [4]
20/9 20/10 26/12 65/7,
confirm [1] 1/15
confirmed [5] 1/12
1/17 31/7 41/9 76/24
conflict [3] 100/15
100/17 101/17
conflicting [1] 14/17
confront [1] 51/5
conglomerate [1]
60/15
connection [5] 6/17
39/15 40/1 43/5 59/1
consequence [1]
61/17
consequences [3]
67/15 68/18 90/14
consider [6] 13/13
25/21 37/3 62/7 76/20)
87/11
considerable [2]
28/9 30/1
consideration [1]
14/25
considered [4] 37/6
39/20 47/13 50/24
considering [2] 59/7
89/20
consistent [2] 9/24
22/19
conspire [1] 36/23
conspired [1] 37/2
conspiring [1] 37/7
constrained [1]
20/12
consultation [4] 53/6
53/7 53/15 62/8
contained [2] 39/9
92/22
contains [1] 70/9
contempt [1] 38/16
content [2] 31/22
49/3
context [8] 24/8
53/14 61/5 66/1 66/6
66/21 76/13 82/22
continue [2] 4/5
83/23
continued [4] 1/3 1/4
108/1 108/3
continues [1] 8/4
continuity [1] 30/19
contrary [1] 50/12
contrast [2] 87/4
87/4
contributed [1] 49/24)
control [1] 21/14
convenient [1] 50/7
conversation [7] 3/1
4/25 47/23 68/9 70/13)
92/9 92/10
convict [2] 28/10
7712
convicted [6] 43/22
54/16 61/2 76/13 80/9
80/16
conviction [3] 74/6
80/13 90/25
convictions [4] 73/12!
76/11 86/8 87/9
convince [1] 3/9
Cooper [8] 18/24
18/25 19/24 19/25
20/15 22/2 22/3 22/16)
cope [1] 74/13
copied [5] 26/3 43/16
(31) case... - copied
Cc
copied... [3] 64/14
71/8 72/3
copy [4] 37/23 44/22
44/23 81/2
Core [1] 35/15
corner [3] 78/19
78/20 78/23
corporate [1] 49/9
correct [28] 1/19
8/11 33/4 41/7 53/23
53/24 59/23 75/7
78/14 82/1 82/2 82/4
82/5 85/12 93/10
94/13 95/19 95/25
97/15 97/21 98/11
98/21 100/16 101/11
102/13 103/7 104/12
107/14
correspondence [4]
2/22 83/10 103/15
103/23
corruption [1] 49/9
Cortes [2] 89/7 92/21
Cortes-Martin [2]
89/7 92/21
cost [3] 7/11 8/24
11/25
costly [1] 7/8
costs [5] 7/6 8/8
10/17 11/24 69/10
could [61] 1/11 1/24
1/25 3/9 4/16 5/17
9/12 10/22 13/16 17/8
17/13 23/22 26/18
27/10 28/6 28/22
28/25 30/8 34/11
35/25 36/15 37/9
37/15 42/3 42/19
46/15 51/2 51/10 52/2)
63/12 64/3 64/10
64/11 64/12 66/10
66/10 67/2 67/6 69/17,
72/15 72/15 72/16
77/8 79/19 79/24
79/25 80/3 81/7 82/3
86/6 86/25 87/1 87/7
88/25 89/9 92/21 93/4
93/10 94/11 103/3
105/4
couldn't [6] 26/24
29/23 32/8 45/23
97/20 103/24
counsel [11] 14/4
16/12 52/7 55/3 57/6
57/15 59/13 89/2
100/13 100/25 104/16}
couple [3] 21/8 30/24
44/6
course [19] 8/15 10/8)
33/17 50/10 53/13
53/19 63/21 65/21
70/17 72/17 80/14
81/22 85/18 90/15
91/23 96/6 97/10
99/22 100/10
court [11] 2/20 4/4
4/13 9/24 11/2 11/6
38/16 57/20 77/17
82/6 83/17
cover [6] 1/10 16/14
26/16 48/7 58/23
103/3
covering [1] 42/22
CAR [3] 37/19 38/2
38/8
CQRs [1] 39/1
crawling [1] 57/4
crazy [2] 14/9 14/9
credibility [14] 35/25
38/11 42/18 82/4 92/7
92/15 93/11 94/1
94/12 94/17 95/11
95/13 95/18 95/25
credible [1] 39/6
credit [1] 96/10
creed [1] 51/2
Crichton [2] 55/2
80/23
criminal [45] 21/19
32/7 39/11 39/25
40/14 41/4 41/8 41/13
42/20 43/3 43/6 43/8
44/2 54/5 58/4 58/15
59/17 62/10 67/13
67/20 68/16 68/25
69/1 69/2 69/9 69/12
70/3 71/22 73/21 74/9
76/9 76/19 77/5 77/12
77/13 79/15 79/22
81/21 82/7 82/10
82/19 83/20 94/8
95/12 96/17
criminally [1] 54/16
criminals [1] 36/1
criticism [4] 38/12
38/12 101/15 105/8
criticisms [1] 104/24
cross [3] 77/16 78/8
107/2
cross-reference [1]
77/16
cross-references [1]
78/8
crossover [1] 54/15
Crowe [2] 37/13
92/20
cultural [1] 30/15
curiously [1] 57/17
current [1] 28/23
currently [1] 60/8
cut [4] 27/14 27/22
29/9 34/9
cut-off [3] 27/14
27/22 29/9
cynical [1] 51/23
D
dam [4] 60/21 60/22
73/16 73/23
damages [1] 60/6
damaging [1] 91/2
damn [1] 63/15
damned [1] 60/2
Dan [1] 64/16
dancing [1] 96/17
Daniel [2] 64/14
64/21
dark [1] 36/25
data [8] 41/3 62/23
66/4 90/21 91/6 93/1
93/4 95/7
data's [1] 93/3
data/transactions [1]
62/23
date [7] 16/22 18/2
27/14 27/22 29/9
64/25 88/25
dated [1] 37/11
dates [1] 14/13
David [3] 2/2 58/25
59/6
day [3] 89/14 94/20
107/10
days [1] 13/25
de [1] 37/6
de-emphasise [1]
37/6
dead [1] 5/20
deal [7] 5/5 5/6 12/6
19/22 74/12 77/7
79/20
dealing [2] 66/16
79/17
dealt [5] 33/18 41/21
59/18 66/13 84/7
debate [1] 70/19
deceit [1] 49/9
December [1] 14/14
decide [3] 7/7 11/2
85/16
decided [3] 51/15
69/20 106/5
deciding [1] 106/21
decision [10] 39/12
43/1 43/7 46/17 48/11
85/23 86/2 88/19 99/8
106/20
decisions [8] 5/11
18/3 28/4 36/15 36/16
44/1 84/12 88/22
deep [2] 7/16 105/22
deeper [1] 15/3
deeply [2] 21/13
22/24
defect [1] 63/1
defence [3] 2/17
79/23 86/14
defend [3] 5/3 50/22
91/9
defendants [1] 87/13
defended [1] 51/1
definitely [2] 48/9
87/20
definitively [1]
103/24
degree [1] 9/7
delay [1] 61/21
deliberate [2] 50/17
85/9
delta [1] 52/16
deluded [1] 14/11
demanded [2] 96/9
96/10
demonstrate [1]
79/24
den [1] 37/12
deny [1] 61/22
Department [4]
18/10 18/11 18/17
18/19
departments [1]
30/15
departures [1] 50/15
dependent [1] 75/9
deputed [1] 55/13
derisory [3] 46/21
47/1 47/7
describe [1] 15/15
described [2] 69/24
94/14
describing [2] 15/13
18/9
description [1] 48/20
designs [1] 56/18
desire [1] 26/4
despite [2] 5/3
103/25
detail [2] 23/16 77/23
detailed [3] 77/16
78/8 107/9
details [4] 12/6 25/19
53/9 53/12
determined [2] 2/13
17/18
develop [1] 45/13
developed [1] 52/11
devised [1] 91/19
devolved [1] 32/1
Dickinson [12] 2/12
2/23 3/2 3/6 9/25
21/25 22/5 46/5 61/24,
64/22 70/23 73/1
dictated [1] 59/10
did [56] 2/9 2/9 2/11
3/6 3/14 3/16 4/13
4/15 4/17 5/9 6/3 9/13)
9/14 10/5 10/11 13/12,
16/13 25/18 26/4
26/14 32/3 32/7 32/11
32/19 36/12 36/23
48/8 48/8 50/14 50/17;
51/6 52/5 52/7 52/24
54/3 64/7 65/3 67/23
68/5 70/11 75/25
76/24 80/24 82/13
87/3 91/22 92/16
93/23 95/6 96/16 99/6
99/11 99/13 99/20
104/21 107/2
didn't [35] 5/7 6/11
12/7 26/10 34/9 41/9
43/4 47/7 50/13 51/5
52/8 52/23 54/4 54/13}
54/14 54/19 61/6
62/15 68/7 68/7 68/14
69/21 70/1 74/10
78/20 80/24 88/24
94/18 96/19 98/1
104/18 104/21 104/21
106/6 106/8
difference [2] 9/18
17/1
different [6] 17/10
30/15 36/16 43/10
43/23 47/11
differently [1] 86/23
difficult [8] 17/20
25/24 52/17 91/8
101/9 105/12 106/9
106/13
difficulties [2] 106/14)
106/25
difficulty [2] 106/18
106/19
diligent [1] 56/13
diligently [1] 69/15
diluted [1] 70/4
dim [1] 67/24
dimension [1] 71/13
direct [1] 57/13
direction [4] 5/12
11/3 11/8 103/16
directly [4] 4/12
director [2] 20/4 20/8
directors [3] 18/22
20/2 22/17
dirt [1] 65/13
disclosable [1] 95/12
disclose [11] 39/13
58/1 58/11 72/19 77/3}
79/14 85/24 87/16
94/18 95/17 96/11
disclosed [7] 37/21
63/8 90/22 91/7 93/7
95/21 99/9
disclosing [1] 92/14
disclosure [27] 15/6
20/8 28/4 31/1 43/2
57/18 66/8 66/17
66/18 70/3 73/22
84/13 84/13 85/23
87/12 88/15 88/17
88/18 88/20 88/23
90/6 90/19 91/19
93/24 95/6 95/10
95/15
disclosures [3]
(32) copied... - disclosures
D
disclosures... [3]
39/25 44/2 85/12
discourse [1] 87/12
discovered [1] 48/7
discovering [1] 39/4
discreditable [1]
57/19
discuss [3] 22/1 68/2
72/20
discussed [9] 16/16
16/25 18/1 30/14
31/19 46/15 53/9
58/17 70/21
discussion [7] 16/11
16/22 17/12 19/7
20/17 46/11 71/4
discussions [5] 4/10
4/12 22/25 56/7 57/22)
disgrace [1] 49/10
disingenuous [1]
45/9
dispose [1] 11/18
dispute [1] 17/20
disruptive [1] 7/21
dissent [1] 76/25
dissuade [1] 8/3
diversity [1] 11/21
do [60] 1/11 3/11
AI17 14/7 15/11 16/9
18/16 20/21 21/2 22/3)
23/11 25/16 25/21
31/18 32/2 34/9 34/15
34/16 42/17 43/24
43/25 44/20 49/18
57/1 57/5 58/17 58/19)
59/22 60/2 62/7 62/13
62/20 63/12 65/13
65/21 65/23 65/24
68/4 68/23 75/6 75/17,
76/17 76/21 78/13
85/1 86/17 88/21
92/17 92/25 95/11
97/8 98/25 100/19
101/6 102/17 102/19
102/22 103/4 103/4
106/1
Dobbin [5] 35/2
96/23 96/24 97/2
108/9
Docs [1] 66/2
document [42] 1/23
6/21 6/23 8/22 10/23
11/10 13/18 23/18
28/6 28/23 33/18 39/3
39/10 58/22 59/2 59/4
62/19 70/5 78/21 79/1
79/3 79/5 79/11 80/15)
80/24 81/8 84/24 85/1
85/3 86/4 86/4 86/6
88/16 91/3 91/4 91/10
91/11 91/13 91/13
91/14 95/1 97/6
documents [7] 36/10
45/18 77/20 78/11
89/3 90/19 95/2
does [11] 2/19 5/1
6/1 9/18 13/5 17/22
73/5 74/16 77/22
88/10 97/23
doesn't [3] 24/3 39/3
104/17
doing [9] 14/23 36/6
42/21 45/3 46/25
55/25 84/4 99/11
106/9
domino [1] 63/23
don't [99] 3/23 4/15
4/17 6/6 10/17 16/11
16/23 17/24 18/3
18/18 18/18 21/11
21/11 21/22 22/7 22/7)
22/24 23/15 23/21
24/23 25/9 27/4 27/5
29/22 30/4 31/20
31/21 31/22 32/24
34/12 38/8 38/17
41/24 42/5 42/24
43/11 44/7 45/12 48/3
48/20 49/22 51/7
52/22 52/24 52/25
53/4 53/10 54/25
55/15 57/7 57/9 57/16
57/22 58/23 61/7
61/25 65/11 67/21
69/5 70/13 70/14 71/5)
71/19 73/8 73/11
73/14 73/24 74/1 74/3
74/20 75/8 75/14
75/21 76/2 76/15
76/20 76/25 83/1 83/3
83/24 84/24 85/3
85/17 86/22 86/23
87/20 88/8 92/10
98/14 99/10 99/17
99/18 99/24 100/1
104/4 104/5 106/17
106/19 106/24
don't’ [1] 60/2
done [12] 27/16
27/24 32/21 44/13
62/16 65/22 68/12
69/19 76/1 87/24 88/2
88/13
dots [1] 40/6
doubt [4] 42/1 80/11
80/18 87/18
doubts [1] 103/9
down [32] 1/20 4/21
13/17 17/15 19/9
19/24 20/6 21/23 22/9)
25/10 26/21 28/25
29/7 30/13 37/9 37/15)
37/16 38/20 64/11
64/12 66/10 66/11
66/25 67/3 67/18
69/22 69/25 70/1 73/1
77/11 78/10 89/10
downplay [7] 36/24
37/7 38/22 39/7 40/2
40/5 43/19
downplaying [1] 39/6]
downsides [1] 8/8
dozen [1] 46/3
Dr [2] 86/10 87/15
Dr Gareth [2] 86/10
87/15
draft [3] 24/3 27/12
87/6
drafted [4] 74/11
78/20 82/17 88/16
drafting [1] 82/18
draw [2] 38/18 72/12
drawing [3] 15/21
37/22 40/1
draws [1] 38/10
drew [1] 6/17
drop [2] 12/17 13/3
DSARs [1] 66/2
dual [1] 79/7
due [1] 88/17
dump [2] 16/15 17/1
during [4] 10/19
13/24 33/17 49/14
duties [10] 9/24
22/18 31/12 57/20
75/7 75/13 75/13
75/14 82/6 96/13
duty [8] 28/1 31/1
31/15 75/5 75/12
76/21 81/18 83/16
E
each [4] 11/20 11/22
37/3 46/8
earlier [4] 42/15
74/18 80/7 97/22
early [2] 4/24 93/20
easily [1] 5/11
effect [6] 2/21 9/3 9/9
10/1 10/6 63/23
effectively [1] 40/16
efficacy [2] 57/25
58/10
eg [1] 30/17
eg turn [1] 30/17
either [6] 6/2 6/25
12/10 61/2 87/22
104/19
element [1] 48/9
elephant [1] 96/18
Elizabeth [1] 23/23
elliptical [1] 93/25
else [5] 5/10 6/11
23/14 75/23 104/5
email [44] 2/1 2/1
3/22 3/22 3/25 4/14
4/21 11/15 13/22
16/14 16/18 17/10
19/3 23/23 24/25 25/9}
25/11 37/11 37/16
40/8 40/10 41/14
41/16 42/18 43/14
43/17 52/6 52/10
58/23 65/19 67/2 67/4
67/7 70/8 88/12 92/20
94/20 94/23 94/23
97/7 97/12 98/8
103/20 103/21
emailed [2] 20/12
49/5
emails [9] 6/9 26/3
49/4 64/17 64/20 65/3)
65/5 65/24 103/14
emerge [1] 37/14
eminently [1] 89/23
emphasise [2] 37/5
37/6
enable [1] 40/18
end [7] 5/20 19/10
63/25 64/10 65/4 69/7
73/9
ended [2] 16/23
52/23
engage [1] 45/6
engagement [2] 22/1
50/23
England [1] 32/7
enormously [1]
40/23
enough [1] 59/6
Enright [2] 49/6 50/2
ensuring [1] 34/13
enter [1] 47/5
entire [2] 12/3 17/10
entirely [1] 38/25
entities [2] 12/16
13/2
entitled [2] 6/21
28/16
envisaging [1]
106/14
epitome [1] 49/8
errors [3] 48/23
50/14 91/22
especially [1] 42/19
essential [2] 3/4 24/4
essentially [3] 36/7
42/21 46/24
establishing [1]
70/24
et [6] 16/5 31/13 68/5
68/5 78/9 78/9
et cetera [6] 16/5
31/13 68/5 68/5 78/9
78/9
etc [2] 15/8 30/21
ethical [1] 75/7
ethics [1] 38/16
ethics/contempt [1]
38/16
even [3] 16/16 86/17
87/4
event [1] 16/21
events [4] 51/10 56/8
80/5 83/25
eventually [1] 12/5
ever [10] 10/18 16/23
26/4 75/25 98/14
99/11 99/14 99/20
100/7 100/8
every [2] 15/5 47/13
everybody [2] 45/19
89/17
everyone [3] 14/2
14/3 14/8
evidence [38] 2/9
3/12 5/16 6/10 6/14
6/15 18/8 38/7 38/11
41/25 48/1 48/13 49/3
49/7 49/8 53/5 64/4
65/20 66/23 79/21
82/8 82/11 82/24
83/17 86/10 87/3
87/14 88/7 90/5 92/1
96/1 100/3 104/8
104/11 104/24 105/16)
105/19 106/12
exact [1] 72/11
exactly [1] 79/4
examined [1] 98/12
example [10] 6/12
6/14 16/3 22/5 49/20
61/3 64/20 69/23
103/14 106/10
exchanging [1] 2/4
excluded [1] 80/1
exercise [1] 71/12
existence [2] 79/23
96/12
expect [1] 48/7
expectation [3]
52/12 54/1 105/13
expected [1] 7/19
expecting [1] 5/4
expedition [1] 48/13
expensive [1] 17/20
experienced [3] 7/16
17/4 96/17
expert [17] 39/5 58/2
58/12 59/14 59/25
77/4 79/23 80/2 80/18}
85/8 86/10 87/14
93/12 96/13 100/7
100/22 101/20
explain [7] 24/8 25/5
47/21 64/3 70/14 74/5
99/6
explained [10] 9/23
10/3 10/23 47/18
52/10 56/20 65/15
71/4 92/13 105/11
explains [2] 8/12
11/5
explanation [2] 47/24)
68/19
exploded [1] 90/7
exposing [1] 106/8
express [1] 46/1
(33) disclosures... - express
E
expressed [6] 3/25
20/14 23/9 26/7 35/20)
52/18
expression [3] 57/5
57/8 69/10
expressly [1] 16/13
extent [2] 25/21
49/24
external [5] 18/13
84/22 85/6 85/21
89/22
extra [1] 28/5
extraordinary [1]
96/16
extremely [3] 3/8
11/24 14/3
eye [1] 12/25
F
fact [18] 13/2 38/3
38/5 60/23 69/13
70/22 85/20 85/23
91/3 94/21 97/4 97/25
99/8 99/15 99/21
104/2 105/9 105/12
factor [2] 10/6 13/13
factors [1] 14/25
facts [2] 82/15 84/6
fail [1] 71/18
failed [3] 48/6 82/6
87/15
failure [5] 52/23 95/8
95/22 96/11 96/12
fair [10] 8/10 10/13
13/12 42/24 48/11
51/7 51/24 54/6 88/8
104/16
fairly [2] 36/20 47/4
faith [5] 45/10 46/18
47/13 47/15 48/22
Falkirk [6] 77/22
78/15 78/16 79/21
97/21 97/24
fall [1] 32/11
false [5] 60/6 61/4
80/8 82/8 83/8
familiar [2] 59/3 90/4
far [8] 5/17 24/18
25/22 75/24 84/11
85/10 85/24 105/2
fast [1] 88/19
fault [2] 48/10 64/2
faults [2] 63/4 79/24
favour [2] 8/5 65/17
favourable [1] 7/18
Fawcett [4] 64/14
64/19 64/21 65/22
feasible [1] 12/7
February [2] 64/13
93/20
feed [1] 35/19
feeding [1] 64/18
feel [4] 9/1 66/16
70/11 79/13
feeling [1] 8/2
feels [1] 5/2
fees [1] 12/12
felt [1] 65/16
few [7] 1/9 1/21 2/10
11/16 15/8 35/2 46/25
fictitious [1] 60/25
fifth [1] 15/1
fight [1] 12/21
figure [1] 69/15
figures [1] 40/20
final [4] 23/18 29/12
31/24 48/25
financially [1] 12/12
find [6] 4/7 14/10
40/7 50/1 58/17 58/19)
finding [1] 67/4
findings [7] 59/25
60/3 60/5 60/18 77/15
78/8 79/14
fine [2] 34/1 34/6
finish [1] 74/16
finishes [1] 14/13
firm [6] 29/20 36/17
56/24 60/15 97/14
100/12
firm's [6] 78/24 79/1
79/8 79/10 101/2
101/17
firms [3] 32/19 60/15
60/16
first [17] 1/23 5/13
25/8 26/20 28/7 28/24
31/6 33/7 33/9 34/23
61/7 72/13 89/12 95/5)
97/4 99/17 100/10
fishing [1] 48/13
fixed [1] 80/6
flagrant [1] 70/12
flawed [3] 61/10
61/18 73/19
flexed [1] 15/22
floodgates [4] 60/5
60/20 62/10 63/13
flow [2] 11/7 21/14
flowed [1] 102/2
focus [3] 33/19 78/19
81/22
follow [1] 83/11
followed [5] 12/5
27/5 33/24 33/25
81/16
following [4] 24/17
43/2 71/16 96/9
follows [5] 2/2 15/20
17/17 95/16 104/17
footnote [1] 94/22
footnoted [1] 94/21
footnotes [1] 95/3
force [4] 12/8 15/24
16/9 61/2
forced [1] 61/3
forces [1] 14/22
forget [1] 53/13
Forgive [1] 86/15
form [1] 14/21
formal [4] 66/13
84/22 85/6 89/22
formally [1] 66/14
formulated [1] 19/11
forward [6] 14/10
16/13 59/6 70/8 83/24
88/19
forwarded [1] 65/19
forwarding [1] 65/22
forwards [1] 66/10
found [8] 61/10 61/18
62/3 63/18 64/16
73/13 73/19 74/6
Fraser [4] 13/25
14/23 17/17 91/3
free [1] 13/25
freely [1] 22/6
Freeths [4] 2/13 10/2
12/12 12/18
Friday [2] 1/1 30/14
friend [2] 6/10 97/5
froing [1] 70/24
front [2] 76/15 83/1
fruition [1] 18/2
frustrating [1] 46/16
fudging [1] 70/22
FUJ00160244 [1]
416
FUJ00182096 [1]
3/23
FUJ00182166 [1]
1/25
Fujitsu [16] 2/6 6/4
6/13 40/22 80/3 86/11
87/15 91/4 103/15
104/3 104/5 104/6
104/7 104/10 104/22
105/17
Fujitsu's [1] 98/25
fulfil [2] 24/4 24/12
full [4] 9/12 11/22
14/4 24/13
fullness [1] 11/19
fully [3] 52/11 52/18
93/5
function [1] 24/4
fund [1] 7/19
fundamental [5]
63/18 75/5 75/8 75/11
81/18
fundamentalist [2]
51/3 51/4
fundamentally [3]
61/10 61/18 73/19
funder [7] 7/7 7/15
7/16 10/3 12/14 12/19
60/10
funding [2] 12/25
15/10
further [10] 21/9
29/12 37/16 41/14
58/7 66/11 67/3 76/18
83/10 87/12
future [5] 14/15
46/24 47/3 47/6
102/19
G
gaps [1] 51/5
Gareth [51] 2/24
37/22 38/4 38/6 38/11
39/10 39/15 40/1 40/7,
41/6 41/7 41/10 42/18)
43/4 43/20 53/20
53/21 57/20 75/17
77/2 80/2 80/18 80/22,
81/12 83/16 84/2
85/25 86/10 87/15
89/16 89/18 91/25
92/6 92/15 93/11
93/20 93/25 95/1
95/11 95/14 95/18
95/25 97/2 103/10
104/8 105/1 105/15
105/18 105/23 106/4
106/15
gather [1] 75/25
gathered [1] 51/18
gave [6] 2/16 7/12
22/22 82/24 83/17
88/7
Gavin [9] 27/4 29/24
56/19 57/14 61/15
72/13 72/17 73/14
89/6
general [12] 11/8
14/16 25/20 30/5 55/2!
55/5 74/7 84/21 91/24)
92/4 93/14 96/3
generally [2] 9/23
44/13
generate [1] 5/3
gently [4] 67/5 67/11
67/23 68/15
genuine [1] 52/3
get [18] 5/6 12/20
25/6 25/15 51/20 54/2
58/24 61/22 62/12
62/18 65/3 68/3 84/13)
86/5 88/20 89/1 89/8
105/15
getting [5] 44/20
48/11 85/20 103/10
106/17
give [22] 2/20 6/14
7/8 19/8 21/24 26/4
26/10 38/20 44/16
50/8 52/14 70/7 73/19
T4I7 76/7 84/3 84/20
87/3 87/25 92/2
105/19 106/12
given [31] 3/20 5/5
6/10 11/21 17/25 18/8
26/18 33/12 36/25
42/19 49/3 58/19 61/4)
68/19 82/8 82/11
84/14 84/17 84/20
85/5 88/18 90/5 93/16
96/3 99/14 99/15
100/24 101/16 104/24)
106/5 106/10
gives [3] 83/8 84/21
85/5
giving [7] 3/12 6/15
17/23 40/2 75/16
76/19 85/21
go [30] 8/7 11/18
23/15 29/7 29/14
34/16 34/21 37/15
47/21 52/5 53/3 59/12
64/10 66/7 67/1 67/6
70/8 71/7 72/15 72/16I
76/18 77/8 79/11 86/6
87/5 87/7 95/2 95/6
97/6 103/2
Godeseth [1] 105/16
goes [1] 43/25
going [29] 1/8 1/21
14/5 18/6 26/17 41/14)
44/5 44/6 46/7 50/12
54/2 54/7 55/1 56/23
63/23 63/25 67/10
68/4 72/5 74/23 83/24I
84/9 91/17 92/2 92/12I
96/8 97/6 102/24
103/2
gone [3] 79/6 90/10
98/12
good [13] 1/5 35/14
45/10 46/17 47/12
47/15 48/22 52/24
53/1 69/22 84/22 85/5
89/21
got [14] 13/9 19/18
33/11 44/22 44/24
64/9 64/13 64/19
77/25 79/4 81/3 83/1
88/23 91/18
Government [3] 9/19
18/7 25/21
grab [1] 13/25
Graham [1] 4/22
grateful [3] 60/13
74/14 107/11
great [2] 5/5 54/1
greater [1] 39/24
grenade [4] 63/24
84/8 84/9 84/9
Gribble [1] 2/22
ground [1] 76/7
grounds [5] 84/22
85/5 89/21 90/11 91/1
group [12] 6/5 6/22
11/3 32/15 32/16 47/8}
51/9 51/20 62/15
66/22 71/16 105/14
grudging [1] 51/23
guess [3] 39/13 43/1
(34) expressed - guess
G
guess... [1] 101/12
guilty [2] 61/3 80/8
H
had [117]
hadn't [6] 43/19
71/25 91/24 104/10
105/23 105/24
haggard [1] 45/21
half [4] 23/20 34/3
34/4 107/10
halfway [3] 4/21
17/15 30/13
Hamilton [1] 90/17
hand [11] 7/13 29/7
29/10 29/15 29/15
29/16 29/17 38/8
78/19 78/20 78/23
handle [1] 67/16
handled [2] 23/1 26/1
handling [2] 3/2
61/15
handwriting [5]
26/23 28/25 29/2 29/3
55/7
handwritten [3]
26/22 28/20 29/13
hang [2] 55/21 74/15
happened [5] 5/7
16/21 45/16 77/11
78/10
happens [1] 76/19
happy [6] 4/5 14/23
34/17 34/18 41/19
42/7
hard [3] 5/10 44/22
44/23
hare [1] 69/17
hares [1] 68/11
has [39] 2/17 2/19
17/18 18/8 19/22 20/9)
20/10 25/4 28/5 28/11
28/15 28/18 29/12
29/18 33/18 34/14
35/2 37/23 45/15
47/25 57/25 58/10
63/4 64/19 69/4 76/4
78/23 80/12 86/24
87/11 87/24 88/12
89/12 92/22 92/25
94/6 97/5 99/4 100/3
hasn't [3] 44/16
55/21 83/19
have [158]
haven't [9] 44/24
49/1 50/4 55/16 55/18)
81/1 83/1 90/24 98/2
having [10] 12/5 19/7
21/8 36/9 41/25 47/13,
47/23 77/20 85/12
103/4
he [105] 2/2 2/6 2/8
2/9 2/9 2/13 2/19 2/19
2/20 3/3 3/8 3/14 3/16
3/25 4/14 4/22 5/1 5/1
5/2 5/4 5/5 5/6 5/7 6/1
6/7 6/9 6/10 18/10
19/25 20/2 20/11
24/13 27/5 29/25
31/11 41/17 41/21
41/24 42/2 42/7 42/17
42/19 42/19 45/16
45/16 45/18 45/22
45/23 45/24 48/16
55/4 55/5 55/6 55/11
55/21 55/21 56/20
64/23 67/12 67/13
67/16 67/22 67/25
68/1 68/5 68/7 68/7
68/10 68/10 68/15
68/16 69/20 70/11
70/23 71/11 73/3
74/11 76/5 82/9 82/11
83/2 83/17 83/19 87/3
91/22 92/13 93/12
93/15 93/21 94/17
94/18 97/7 98/1 99/14)
99/15 99/20 101/8
102/4 104/19 104/21
104/21 104/22 104/24)
105/2 106/15
he'd [1] 94/12
he'll [1] 68/11
he's [6] 54/25 64/22
71/12 83/3 94/6 95/4
heading [1] 66/8
hear [3] 1/5 35/11
107/13
heard [5] 5/25 6/14
46/21 69/14 100/10
hearing [2] 11/2
107/18
heart [1] 85/22
heavily [3] 58/5 58/6
67/19
heavy [2] 67/14
68/17
Helen [20] 37/19 38/4
38/14 38/19 38/23
38/25 39/8 39/14
39/16 40/3 40/16 41/1
43/3 75/19 91/20 92/5
92/14 92/25 93/17
94/4
Helen's [1] 93/7
help [8] 5/8 53/4 60/9
62/16 64/9 67/19 73/5)
75/16
helped [1] 36/6
helpful [1] 24/7
helps [1] 95/15
hence [2] 70/8 88/15
Henderson [2] 64/21
107/13
Henry [14] 33/25
33/25 34/6 34/8 34/15
50/6 50/11 55/22
74/15 75/3 96/20 97/5
99/4 108/7
Henry's [1] 102/10
her [10] 76/7 80/16
81/10 85/3 88/18 90/7
90/10 90/22 92/25
99/9
here [9] 10/14 16/7
16/16 23/6 35/17
37/16 39/24 66/1
106/14
herself [1] 76/14
high [5] 8/25 11/24
23/15 63/11 69/25
high-level [1] 69/25
hest [1] 59/15
highlight [2] 9/7
37/25
him [26] 2/16 5/4
20/6 45/16 45/20
45/22 56/20 67/23
68/10 68/15 73/2 82/3
93/18 94/20 94/23
99/22 101/11 103/8
103/11 104/25 106/1
106/2 106/6 106/9
106/9 106/11
himself [3] 5/2 30/6
70/11
his [39] 2/7 5/12
20/12 35/10 38/6
45/19 48/2 49/8 55/7
58/2 58/12 65/22
70/19 70/24 71/2
72/13 73/4 73/10 74/2
77/4 82/3 82/6 83/16
83/20 91/22 94/11
94/23 95/16 95/22
96/3 96/12 96/13
99/19 101/6 102/12
103/12 105/23 106/3
106/16
historic [4] 6/12
84/23 89/22 104/23
history [1] 52/19
hits [1] 5/20
hm [2] 23/10 42/16
hog [1] 96/8
hold [2] 65/3 105/24
holding [6] 72/7 72/9
82/17 82/18 82/21
83/9
Holloway [4] 45/15
45/21 46/2 49/21
Holt [1] 89/6
Holyoak [1] 64/20
hope [5] 7/6 34/4
47/18 62/21 95/15
hopefully [2] 47/21
67/17
Horizon [49] 2/11
14/14 27/15 27/16
27/23 27/24 31/9
36/20 38/5 39/5 42/1
48/14 50/24 51/11
51/25 58/1 58/11
59/15 59/19 60/3
60/19 61/10 62/23
63/1 63/4 63/18 64/2
73/18 77/14 77/23
79/5 79/14 79/24 86/4
87/16 90/16 90/16
91/1 91/9 91/15 93/9
93/12 93/13 93/21
94/11 95/8 95/20
97/18 105/20
Horizon’ [1] 59/18
Horizon-based [1]
39/5
hour [7] 1/8 34/3 34/5)
34/6 34/11 34/16
91/18
house [4] 17/4 23/1
26/2 79/1
how [18] 3/19 17/8
19/11 21/2 21/9 26/15}
27/1 32/23 34/21 54/1
58/6 65/3 67/16 83/25)
90/10 92/5 105/4
106/22
Howe [8] 35/16 37/19
37/24 38/13 39/4 40/6)
40/23 41/1
however [9] 2/9 9/13
10/5 38/16 39/22
52/15 55/12 77/22
82/21
hub [1] 31/8
hundreds [5] 43/21
60/22 60/22 60/22
61/1
laccept [4] 36/13
47/19 52/16 53/16
l accepted [2] 63/10
97/22
l advocate [1] 10/5
lalso [4] 2/24
l always [1] 64/12
lam [8] 4/5 5/1 25/3
36/21 41/19 42/7
75/24 102/18
I apologise [3] 36/17
49/16 49/25
I apologised [1]
49/16
l appreciate [1] 14/3
lare [1] 4/24
lask [4] 34/15 35/14
58/7 72/15
l asked [1] 62/7
lassume [1] 90/1
I began [3] 15/16
51/8 61/25
I believe [14] 32/6
33/8 40/10 41/4 48/6
48/10 66/21 69/5
69/20 73/17 91/12
94/19 107/6 107/13
Ican [45] 1/6 14/17
33/19 35/9 35/13
46/15 53/7 64/25
73/12 84/11 85/10
86/20 97/1 102/14
105/3
I can't [27] 3/16 3/20
4/12 29/24 31/17 32/9)
32/21 32/21 42/12
53/8 55/6 66/1 72/8
72/10 76/4 76/16
77/120 78/14 79/2 81/4I
90/10 94/2 94/19 98/2
103/20 104/20 105/1
I could [3] 34/11 52/2)
103/3
I couldn't [3] 26/24
29/23 103/24
I defended [1] 51/1
I described [1] 94/14
I did [5] 2/11 4/15
16/13 25/18 82/13
I didn't [7] 6/11 12/7
34/9 54/13 61/6 74/10
106/6
Ido [7] 1/11 34/9
43/25 58/19 62/20
78/13 95/11
I don't [75] 3/23 4/15
6/6 10/17 16/11 16/23}
17/24 18/3 18/18
18/18 21/11 21/11
21/22 22/7 22/7 22/24)
23/15 25/9 27/4 27/5
29/22 30/4 31/20
31/22 32/24 38/17
42/5 42/24 43/11
45/12 48/20 49/22
51/7 52/22 52/24
52/25 53/4 54/25
55/15 57/7 57/9 57/16)
57/22 61/7 61/25
65/11 67/21 69/5
70/13 70/14 71/5
71/19 73/8 73/14
73/24 75/14 75/21
76/2 76/15 83/1 84/24I
85/3 86/22 86/23
87/20 88/8 92/10
98/14 99/10 99/17
99/18 100/1 104/4
104/5 106/17
lever [1] 10/18
l expect [1] 48/7
l explained [6] 47/18
52/10 56/20 65/15
71/4 105/11
I felt [1] 65/16
I first [1] 99/17
I followed [1] 81/16
I gently [1] 68/15
(5) guess... -I gently
I
I got [1] 13/9
I guess [3] 39/13
43/1 101/12
I had [10] 3/1 6/7
13/9 25/24 26/13 62/1
65/16 70/14 71/5
76/23
I hadn't [1] 104/10
Ihave [10] 4/2 4/24
18/15 25/13 41/16
49/13 50/1 56/11
57/12 67/11
I haven't [5] 50/4
55/16 81/1 83/1 98/2
I highlight [1] 9/7
I hope [2] 34/4 47/18
lindicate [1] 33/17
lintended [1] 33/19
linvite [1] 50/6
I just [8] 1/9 3/24
8/20 34/10 50/1 53/11
99/3 105/4
I knew [2] 6/6 56/20
I know [1] 4/19
Hook [1] 36/14
I made [1] 49/24
I may [6] 32/21 50/2
62/16 81/5 97/3
102/25
I mean [11] 50/14
53/14 54/1 54/3 56/4
56/12 56/17 57/10
69/23 78/9 91/8
I never [1] 37/2
I note [1] 78/22
I now [2] 32/18 92/19
l omit [2] 77/19 93/2
lonly [1] 100/10
I pinned [1] 78/10
I presume [2] 13/23
89/17
I probably [1] 65/19
I provided [1] 26/15
I put [2] 58/9 77/1
I recall [14] 18/19
18/21 23/2 23/13 30/5)
31/22 44/11 53/7
70/21 71/3 76/9 83/25
94/24 100/17
l recognise [1] 49/23
I recognised [1]
54/15
I recommend [1]
9/13
I recommended [1]
8/24
I remember [3] 27/6
66/3 70/5
I represent [1] 97/2
I said [5] 41/12 63/16
74/9 90/1 101/4
I saw [2] 9/20 84/18
I say [12] 17/24 36/16
43/9 43/25 47/12
65/21 71/24 72/10
81/1 86/1 102/1 105/1
Iset [1] 16/18
I spoke [1] 94/24
I started [1] 74/17
I suggest [4] 59/8
61/20 70/10 88/25
I supervised [1]
44/14
I suppose [1] 49/11
I suspect [4] 11/11
29/23 56/2 63/17
Itake [1] 54/22
I think [78] 3/18 8/19
10/23 13/7 13/8 13/14
13/18 14/9 15/21
16/12 16/15 17/3 17/9)
18/10 18/22 23/20
23/25 25/18 26/7 27/5
27/6 27/7 33/8 34/8
35/20 39/8 42/14
42/25 42/25 43/14
43/25 44/19 47/4
47/10 51/8 51/24
52/24 60/11 61/8
61/17 62/20 63/10
64/11 64/24 65/1
65/18 66/22 69/13
69/14 70/5 73/7 74/5
T4I17 74/18 74/19
77/11 78/2 78/10
78/15 86/22 87/6
87/21 96/21 97/12
97/14 97/23 97/25
98/18 98/19 98/24
98/25 101/1 102/10
103/4 104/16 105/1
105/21 106/4
I thought [2] 24/7
63/5
I took [1] 16/6
I tried [2] 5/9 70/14
I understand [1]
58/14
l understood [7] 20/3
32/8 36/19 41/1 74/5
91/11 94/3
lused [2] 16/15
36/14
I want [14] 1/23 6/19
37/25 44/4 53/3 56/22
58/22 59/2 59/12 71/7,
74/12 77/7 86/3 95/2
I wanted [5] 97/3
99/4 103/3 103/13
104/9
Iwas [21] 11/11 12/4
20/18 20/25 22/24
29/22 41/12 45/5 51/9
54/6 54/20 65/1 81/2
82/18 88/22 91/25
96/15 104/6 104/9
105/2 105/17
I wasn't [5] 31/17
54/5 81/20 84/12 86/2
I will [3] 4/6 72/13
97/10
I won't [2] 76/18
98/16
I wonder [2] 55/20
101/12
I would [8] 8/11
10/14 21/5 40/9 56/2
64/25 76/23 78/11
I wouldn't [2] 15/15
57/15
I'd [6] 7/3 15/1 34/18
43/15 65/14 74/19
rl [9] 11/16 19/9
34/22 45/1 45/3 45/13)
49/14 87/25 98/6
I'm [51] 1/8 1/21 14/5
14/8 18/6 18/15 20/18
21/11 21/17 25/3
26/17 42/12 43/6 43/8
43/8 44/5 44/6 50/12
50/21 53/11 54/8
56/23 57/23 59/5
60/13 62/21 63/23
66/1 67/3 67/4 74/13
76/12 76/15 86/15
86/23 86/24 91/14
91/17 92/2 92/12 97/5
97/9 101/16 101/25
102/18 102/24 103/2
104/13 106/14 106/15}
107/11
I've [19] 33/11 34/23
37/18 40/11 44/22
54/5 64/9 68/19 73/17
74/5 77/11 78/22
83/12 91/18 93/14
93/16 95/5 96/3 98/14
lan [1] 64/20
idea [4] 17/25 51/19
89/20 107/2
ideal [2] 5/18 105/12
ideas [2] 16/15 17/5
identified [2] 30/24
59/21
identify [2] 77/13
78/12
identifying [1] 77/17
ie [1] 84/23
ie by [1] 84/23
if [119]
ignore [2] 40/5 43/20
ignoring [1] 38/25
ii [1] 15/25
immediately [1]
59/21
impact [5] 9/1 73/4
73/9 74/2 92/6
impacted [1] 54/11
implication [1] 93/19
implied [1] 65/7
importance [2] 38/23
40/3
important [9] 24/8
30/17 36/24 37/4 37/8
39/8 40/23 70/5 101/1
impossible [1] 63/22
impressed [2] 56/14
56/15
impression [4] 13/9
15/16 24/22 26/13
impressions [1] 26/4
impressive [1] 71/11
imprisoned [1] 60/6
imprisonment [1]
80/12
improperly [1]
102/23
impugn [1] 92/15
inaccurately [1]
62/23
inappropriate [2] 9/4
9/6
include [1] 9/11
included [1] 25/8
includes [1] 24/19
incompatible [1]
75/15
increase [2] 7/5 8/4
increasing [1] 8/1
incredibly [1] 91/8
incumbent [1] 70/11
incur [1] 10/17
indeed [2] 9/2 102/15)
indefensible [3] 83/5
83/14 85/4
independent [2]
59/14 71/21
indicate [1] 33/17
indicated [2] 28/11
66/23
individual [3] 9/5
12/6 88/23
individually [1] 11/21
individuals [8] 6/4
6/13 8/3 28/2 28/11
28/13 30/25 31/12
indivisible [1] 96/11
inevitably [2] 96/9
96/10
inference [1] 42/7
influence [1] 18/13
inform [1] 101/7
information [56] 2/25]
4/6 4/8 13/10 20/7
20/12 20/16 20/23
20/25 21/2 21/14
21/19 23/14 23/25
24/13 25/25 26/5 26/9)
26/12 28/14 39/9 41/2,
52/14 64/16 66/8
66/19 68/4 68/5 68/7
68/8 81/11 85/15
85/15 92/24 99/20
99/21 100/8 100/20
100/20 100/23 101/5
101/7 101/9 101/10
101/13 101/21 101/24!
102/2 102/4 102/6
102/9 103/6 103/10
103/18 105/6 106/5
infrequently [1] 10/6
initial [1] 13/22
input [2] 11/12 81/5
inputting [1] 40/21
inquiry [15] 6/15 18/8)
33/20 35/16 35/17
38/10 48/1 52/7 54/18)
89/3 90/15 100/3
100/11 102/14 107/11
inseparable [1]
96/12
insertion [1] 91/5
insertions [1] 90/20
insincere [1] 51/23
insofar [2] 9/1 77/24
instead [6] 36/5
38/22 68/14 83/21
91/17 91/19
instinct [1] 15/10
instruct [2] 9/15
59/14
instructed [8] 32/20
65/21 70/23 84/3
100/7 100/22 101/20
102/23
instructing [1] 65/23
instruction [5] 70/6
78/5 100/13 100/24
103/16
instructions [8] 46/1
46/6 46/20 47/16
50/24 58/8 62/1 71/2
insurers [4] 12/14
12/19 79/8 88/15
integrity [1] 93/21
intelligent [1] 96/6
intended [2] 33/19
83/9
intention [6] 28/12
47/19 47/21 48/10
48/22 83/10
interest [1] 68/25
interested [3] 54/6
54/8 54/9
interests [1] 50/22
interim [6] 53/19
62/3 72/20 79/14
82/23 83/22
internally [1] 46/11
interrelation [1] 74/8
into [14] 4/1 12/9
28/18 37/22 38/10
47/5 47/12 47/16
48/21 52/12 78/22
81/5 81/7 105/22
intractable [1] 17/20
intrusive [2] 19/21
19/23
(36) I got - intrusive
invariable [1] 56/4
investigate [2] 81/1
91/14
investigating [1]
52/25
investigation [6]
38/24 52/12 52/13
69/1 85/17 89/24
investigations [1]
81/7
invite [1] 50/6
involve [1] 45/2
involved [12] 2/17
22/24 29/22 53/14
56/7 58/6 58/6 61/6
76/6 82/9 86/2 86/5
involvement [4] 32/5
32/19 70/15 71/5
involving [1] 28/10
Ireland [5] 31/24 32/4I
32/10 32/11 32/15
irrelevant [1] 37/6
is [228]
isn't [30] 5/16 12/23
16/14 39/7 40/2 40/8
40/25 42/7 43/12
43/13 43/18 44/15
46/2 46/7 48/16 57/8
73/16 79/1 79/9 82/14
82/25 83/6 83/25
84/10 85/9 86/21
88/20 98/19 101/15
102/5
issue [29] 3/11 13/13
16/19 20/21 20/25
22/7 25/17 31/18
39/11 39/16 43/20
54/10 54/11 59/16
67/18 79/14 89/21
90/2 92/16 93/6 93/19
95/8 95/10 95/13
95/18 95/25 100/6
100/10 100/21
issues [42] 1/24 6/12
13/24 14/13 14/14
17/14 19/17 20/10
21/5 21/7 22/17 25/5
26/16 30/17 30/22
31/3 31/9 36/25 37/3
37/4 37/5 38/5 38/6
39/19 41/5 41/21
46/15 51/16 58/20
60/3 60/18 83/11 90/4,
90/16 90/17 91/9
93/21 94/25 96/7
96/15 105/19 105/20
issues’ [1] 31/11
it [358]
it's [69] 2/1 4/21 8/18
9/16 11/14 14/9 16/13,
17/11 17/14 18/16
20/18 23/24 26/24
27/20 29/4 33/22
34/13 37/8 37/11
37/16 37/16 39/8 40/2
41/19 42/8 43/10
43/13 43/14 43/18
44/18 47/4 47/15
50/21 51/7 51/24 52/6)
54/6 56/4 57/8 58/24
59/11 60/19 61/17
62/19 62/19 62/20
67/6 67/7 67/9 69/13
70/5 73/16 76/14 79/4
81/2 85/9 89/7 89/14
89/20 91/10 92/3 94/5)
94/7 97/10 98/19
101/1 101/24 102/5
102/10
its [11] 24/12 37/23
46/8 65/5 68/24 69/4
79/23 80/4 89/22
92/14 93/5
itself [1] 84/8
J
Jacobs [8] 33/25
34/1 34/2 34/15 35/9
35/12 44/19 108/5
James [1] 79/13
Jane [2] 24/25 26/8
January [4] 27/14
27/22 28/2 88/19
Jarnail [8] 37/12
41/16 41/24 42/5
42/12 54/25 66/9 89/7
Jay [2] 2/2 4/22
Jenkins [50] 37/23
38/4 38/6 39/10 39/15
40/1 40/7 41/6 43/20
53/20 53/21 57/20
57/25 58/10 77/2 80/2
80/19 80/22 81/25
83/16 86/10 87/15
88/6 89/16 89/18 90/8)
90/9 91/21 93/20
94/12 95/1 95/11
95/14 95/18 97/2
97/25 99/21 99/21
100/7 100/22 101/20
102/13 102/23 103/6
103/11 103/17 103/18)
104/1 104/18 105/15
Jenkins’ [23] 2/24
38/11 41/7 41/11
42/18 43/4 75/17
81/12 84/2 85/25
91/25 92/6 92/15
93/11 93/25 95/21
96/1 96/11 104/8
104/11 104/20 105/41
105/23
job [2] 71/10 101/6
John [2] 6/1 6/6
joined [2] 36/5 36/6
joining [1] 40/6
joint [1] 40/14
Jones [1] 2/2
Jonny [1] 2/22
judge [2] 11/2 61/22
judgement [1] 50/14
judgment [1] 17/13
July [7] 53/22 53/22
77/25 80/22 80/23
97/7 98/8
June [5] 1/1 37/11
43/20 61/5 107/19
June 2012 [1] 61/5
junior [3] 54/23 56/5
64/23
jury [3] 80/9 80/10
80/16
just [64] 1/9 3/24
4/16 5/25 6/8 8/11
8/20 9/16 11/16 15/14]
15/15 17/4 21/8 23/3
23/22 25/13 25/20
26/10 31/4 34/2 34/10)
34/13 35/2 37/13
37/18 40/9 40/10
40/11 44/5 45/1 46/2
47/18 50/1 53/4 53/11
54/21 58/24 59/11
60/9 61/5 62/2 64/9
65/14 66/1 66/25 67/6
75/16 76/13 76/15
78/14 79/11 81/22
82/18 83/9 86/15
92/12 92/24 95/20
98/18 99/3 101/16
103/4 104/9 105/4
justice [6] 17/17
70/12 75/6 75/12
81/19 91/3
K
keep [10] 12/24
13/11 14/23 29/1
36/24 54/12 61/22
67/2 74/23 84/8
keeping [2] 22/21
61/21
kept [1] 22/15
key [8] 8/1 13/1 14/12]
58/20 77/15 78/7
88/25 104/14
kind [3] 12/4 57/5
74/24
kinds [3] 23/11 27/1
29/21
King [23] 30/7 37/18
38/16 39/12 40/4
40/11 43/12 43/15
72/20 72/22 75/22
76/9 81/16 84/18
85/11 87/23 88/3
88/10 88/13 88/16
100/4 100/15 100/18
King's [1] 101/18
knew [11] 6/6 6/10
38/5 42/2 42/3 56/20
82/11 91/23 95/17
99/14 100/20
knock [1] 90/13
knock-on [1] 90/13
knocked [1] 17/5
know [26] 3/23 4/18
4/19 6/11 20/22 27/4
31/15 33/23 42/5 42/9
49/22 51/17 55/10
65/9 69/10 73/14 76/5)
83/17 87/20 88/8
98/20 101/10 104/5
104/18 104/21 106/10)
knowing [1] 106/2
knowledge [8] 1/17
61/12 63/14 91/22
95/21 99/19 104/20
105/2
known [11] 40/24
61/8 63/9 63/14 63/16
90/19 93/8 94/10
94/15 99/13 102/9
L
language [3] 23/7
36/13 49/12
large [6] 50/23 52/16
61/11 63/13 63/19
63/20
largely [2] 1/14 13/7
larger [1] 15/6
last [6] 30/14 43/21
86/11 91/17 92/12
95/8
later [6] 13/7 13/17
61/6 85/19 98/21
105/13
latter [1] 2/23
law [3] 71/22 73/23
83/20
lawyer [10] 36/21
42/20 43/8 44/10
50/21 50/21 58/5
76/19 100/4 100/5
lawyers [30] 2/13
7/23 16/12 16/25 18/1
28/13 39/12 39/25
40/15 40/15 40/24
41/4 41/8 41/13 43/3
43/7 58/4 58/15 64/22)
76/9 77/5 81/11 81/21
82/7 82/10 82/20
85/21 85/24 94/8
96/17
layer [2] 85/20 85/20
lead [2] 16/4 61/11
leading [7] 56/20
57/6 57/15 59/13
100/13 100/25 104/16}
leads [1] 11/19
leaning [1] 65/17
learned [3] 69/25
70/2 97/4
least [8] 12/13 15/6
46/3 56/7 68/7 81/4
81/24 93/17
left [11] 1/22 2/6 2/8
29/7 29/15 29/17
65/12 78/19 78/20
78/23 101/6
left-hand [6] 29/7
29/15 29/17 78/19
78/20 78/23
Legacy [1] 59/19
legal [13] 10/10
13/10 17/6 17/12 23/2)
31/25 60/7 60/10 61/9I
61/11 61/19 72/19
73/20
Lepton [1] 93/19
less [2] 56/8 105/11
lesser [1] 60/25
Lessons [2] 69/25
70/2
let [4] 33/6 45/14
102/5 105/4
let's [8] 19/1 41/14
51/20 53/13 54/21
66/7 75/11 87/4
letter [11] 20/10
43/13 43/13 67/17
69/6 82/17 82/18
82/21 82/25 83/5 83/9
letters [1] 72/11
letting [1] 33/23
level [5] 12/18 13/4
23/15 64/8 69/25
liabilities [5] 61/11
61/19 73/14 73/20
T4I7
liability [1] 51/19
liars [1] 36/1
lid [1] 69/8
light [4] 41/25 81/13
98/21 101/14
lightly [1] 5/11
like [18] 6/18 7/3
15/1 19/9 34/20 48/8
54/3 62/18 63/21 64/7
64/17 71/10 77/21
78/15 78/24 79/10
97/20 101/24
likely [2] 12/16 18/16
limitation [4] 15/25
16/17 16/19 93/5
limited [3] 25/25
79/16 91/19
line [5] 38/10 50/8
56/21 66/2 102/14
lines [2] 51/1 67/11
link [1] 38/3
linked [1] 89/3
Linklaters [2] 59/2
59/8
lips [4] 69/10
litigation [46] 1/22
6/5 6/21 7/2 7/5 7/7
(87) invariable - litigation
L
litigation... [40] 7/8
7/15 7/17 7/19 7/20
7/24 8/2 8/4 8/15 9/11
9/17 9/21 10/2 10/19
11/4 11/23 12/25 13/8)
14/19 17/19 18/13
19/18 19/19 20/22
21/24 24/14 24/21
24/24 25/23 32/15
32/16 47/9 104/15
104/19 105/14 105/19
105/22 106/20 107/1
107/3
itigator [1] 17/4
little [2] 74/18 93/17
live [2] 35/19 71/13
lives [1] 43/21
load [1] 5/7
loads [1] 15/7
locate [2] 55/16
55/24
logic [2] 96/9 96/10
logical [1] 12/19
long [11] 1/9 4/25
7/17 717 8/15 13/22
24/2 53/11 53/13
62/13 98/3
longer [3] 42/3 72/12
82/3
look [20] 1/25 3/22
3/23 5/17 7/3 8/20
16/2 23/23 29/6 29/10
31/5 36/14 37/8 41/14
52/19 55/19 63/12
78/4 78/7 78/22
looked [4] 55/23
55/23 97/20 98/2
looking [11] 25/20
31/5 39/2 43/6 43/8
45/21 66/1 81/14
86/15 101/24 104/9
looks [10] 20/13
21/18 24/1 29/18
64/17 71/10 77/21
78/15 78/23 79/10
losses [4] 60/25 64/3
79/25 80/4
lost [2] 43/23 65/18
lot [9] 11/25 29/18
30/17 45/16 52/24
53/25 66/4 68/12
103/23
lots [1] 45/18
low [1] 8/1
lumbered [1] 51/19
M
M60 [1] 38/2
MacLeod [2] 25/1
26/8
made [43] 1/14 2/19
3/3 18/4 20/10 36/15
36/15 36/17 37/22
37/23 39/12 43/7 44/2
44/7 46/19 46/22
46/25 47/8 49/1 49/15
49/24 53/20 55/6
55/22 62/14 65/2
65/14 68/20 71/25
72/23 81/7 81/21
84/12 87/13 87/22
88/5 88/19 88/22 91/8)
94/25 99/8 103/18
104/25
Mail [1] 51/20
main [2] 30/14 95/9
mainly [4] 23/1 26/1
26/7 106/25
maintain [1] 21/3
maintained [2] 26/11
42/4
make [17] 3/6 9/18
17/18 25/10 26/11
28/3 38/3 38/12 45/23
47/17 49/13 50/13
78/18 85/12 102/2
102/3 104/10
makes [3] 8/23 38/4
52/17
making [5] 21/6
28/20 47/7 105/5
106/20
man [6] 14/1 15/18
16/1 16/11 54/2 71/10
manage [1] 107/1
management [4]
8/14 11/1 90/8 102/12
managing [2] 64/24
65/1
mandate [2] 46/12
47/20
mandated [1] 83/20
manifested [1] 80/5
mantra [2] 42/3 51/2
many [6] 35/18 35/18
45/14 49/2 55/1 87/1
March [2] 14/14 19/5
mark [2] 26/15 64/15
markings [1] 26/22
markup [1] 24/1
martin [3] 30/10 89/7
92/21
material [10] 21/13
58/1 58/11 67/25
68/21 69/21 77/3
77/18 90/18 92/24
materials [1] 78/7
matter [5] 7/25 37/3
42/22 58/4 60/20
matters [5] 6/18 18/3
36/24 37/8 54/20
Matthews [13] 27/4
53/15 53/16 55/12
56/19 57/14 61/15
70/17 71/8 72/17
74/10 77/10 89/6
may [47] 2/13 5/6 8/2
8/21 10/9 10/12 11/6
11/11 11/20 12/21
13/2 13/18 13/23 14/5}
14/24 25/5 25/12
28/13 30/19 31/9
32/17 32/21 38/18
50/2 52/14 52/14
62/16 64/9 65/2 66/5
66/17 72/10 76/3
76/15 79/13 81/5
85/16 86/13 86/19
87/15 88/14 90/10
97/3 99/17 102/15
102/25 105/18
May 2019 [1] 13/23
Maybe [2] 55/8 55/9
me [38] 1/5 6/25 9/15
19/8 19/10 22/8 25/24
33/6 33/12 33/21
33/23 35/11 39/23
44/16 45/14 49/6 50/3,
50/19 53/1 61/7 62/16
63/16 64/9 75/16
76/15 78/21 83/1
86/15 87/25 88/13
90/11 94/2 96/25
99/10 102/5 102/8
102/20 104/4
mean [18] 6/13 32/2
34/9 50/14 53/14 54/1
54/3 56/4 56/12 56/17,
57/10 65/24 69/23
73/6 74/16 78/9 85/1
91/8
means [3] 8/12 74/4
81/3
media [1] 7/25
mediating [1] 45/10
mediation [20] 28/10
32/17 44/5 44/10 45/6}
45/17 45/25 47/5
47/10 47/16 48/6
48/17 48/20 51/15
51/17 52/2 52/9 52/20
65/4 76/6
mediations [10]
44/12 45/9 46/4 46/6
46/12 46/14 47/2
47/12 47/19 47/25
mediator [2] 45/20
45/22
meet [1] 95/14
meeting [24] 4/1 6/23
18/9 18/11 18/14
18/16 18/23 19/3
20/14 25/4 30/3 30/4
30/10 30/10 31/18
31/20 31/21 31/22
31/23 55/6 56/11
66/22 67/25 69/14
meetings [2] 18/18
31/8
member [1] 5/8
members [1] 44/13
memo [3] 77/15 78/7
98/6
memories [1] 53/5
memos [2] 98/2 98/9
mental [1] 14/11
mention [12] 31/14
56/25 57/4 57/13
57/17 57/23 58/16
58/17 89/14 89/15
89/23 99/6
mentioned [7] 33/12
38/6 57/2 82/25 83/2
83/3 85/3
mentioning [1] 84/25
merit [4] 12/22 13/4
13/15 16/20
meritorious [2] 10/7
10/20
merits [4] 7/18 12/17
13/3 46/8
mess [1] 54/2
microphone [2]
33/16 35/10
mid [3] 18/17 43/1
51/9
mid-2013 [2] 43/1
51/9
mid-2016 [1] 18/17
middle [3] 18/9 34/17,
34/18
might [19] 21/9 22/19)
26/15 31/16 34/10
44/23 45/2 49/11
54/17 69/9 69/11 76/7
81/9 87/1 92/5 93/25
100/15 102/19 102/20)
million [2] 14/8 19/21
mind [10] 34/22
42/13 51/10 62/12
73/15 74/11 74/19
74/20 97/9 107/2
mindset [1] 62/8
mine [2] 26/24 29/4
minimise [2] 40/4
43/20
minimising [1] 38/24
minimum [2] 22/15
22/21
ministers [1] 22/13
minute [4] 27/6 47/18)
57/21 57/21
minutes [15] 4/1 27/2
27/3 27/19 28/20
29/19 29/21 29/23
31/17 33/13 34/24
35/3 58/16 74/13
74/16
miscarriage [1]
70/12
miscellaneous [1]
1/9
misfeasance [3]
81/12 81/13 85/25
misheard [1] 104/10
misleading [5] 82/8
83/19 87/7 88/5 93/4
mismatch [2] 90/21
91/5
Misra [28] 28/11
57/14 57/19 58/12
76/1 76/3 76/12 76/14I
777 77/11 77/16
77/22 78/10 78/16
80/8 81/10 82/12
82/25 84/25 86/21
87/19 88/7 88/17 90/5I
97/15 98/5 98/13 99/9I
Misra's [6] 77/25
80/1 85/24 91/7 98/15
99/22
Misras [1] 57/4
misreading [1] 98/9
mistake [1] 78/17
mistakes [4] 36/17
49/15 49/24 50/13
Mm [2] 23/10 42/16
Mm-hm [2] 23/10
42/16
Moloney [1] 33/22
moment [2] 19/8
103/20
Monday [1] 14/6
money [6] 11/25
15/12 15/25 16/9
19/20 19/20
months [3] 18/4
39/13 89/19
months’ [1] 80/12
more [25] 1/21 6/11
7/6 7/20 7/21 9/23
15/4 15/5 19/16 19/23}
20/22 21/23 29/1 37/4I
37/5 38/19 39/23 50/1
50/4 56/8 67/16 73/7
80/6 81/24 87/4
Morgan [1] 59/13
morning [9] 1/5 3/1
4/25 33/9 33/18 35/14)
49/6 81/2 107/12
most [3] 54/22 56/5
68/24
mouth [1] 95/16
move [7] 6/19 18/6
26/17 30/8 31/4 44/4
102/24
moved [3] 16/22 18/2
18/3
moving [1] 25/25
MPs [2] 64/18 71/16
MR [174]
Mr Altman [20] 30/6
30/7 54/2 58/8 66/14
70/11 70/13 70/18
71/9 74/1 75/25 93/15}
93/23 94/6 96/2 101/6I
101/7 101/10 101/12
102/9
(38) litigation... - Mr Altman
Mr Altman's [4] 28/8
70/15 84/21 102/7
Mr Bates [1] 48/5
Mr Blake [10] 33/18
34/25 36/10 41/10
49/4 62/20 69/24
76/18 89/3 107/5
Mr Bourke [1] 64/13
Mr Bowyer [1] 55/9
Mr Chris [1] 59/1
Mr Clarke [5] 55/9
84/16 92/13 94/16
95/17
Mr Cooper [1] 22/3
Mr David [1] 58/25
Mr Enright [1] 49/6
Mr Faweett [2] 64/19
65/22
Mr Henderson [1]
107/13
Mr Henry [14] 33/25
33/25 34/6 34/8 34/15
50/6 50/11 55/22
74/15 75/3 96/20 97/5)
99/4 108/7
Mr Henry's [1]
102/10
Mr Holloway [3]
45/21 46/2 49/21
Mr Jacobs [6] 33/25
34/1 34/2 34/15 35/9
44/19
Mr Jarnail [2] 54/25
66/9
Mr Jenkins [21]
57/25 58/10 81/25
88/6 90/8 90/9 91/21
94/12 97/25 99/21
99/21 100/7 100/22
101/20 102/13 102/23
103/6 103/17 103/18
104/1 104/18
Mr Jenkins’ [4] 95/21
96/11 104/11 104/20
Mr Justice [1] 91/3
Mr Justice Fraser [1]
17/17
Mr Matthews [7]
53/15 53/16 55/12
70/17 71/8 74/10
77/10
Mr Morgan [1] 59/13
Mr Parker [2] 4/11
4/12
Mr Parsons [34] 1/8
33/19 35/14 36/4
36/23 37/10 39/2
43/11 43/18 44/19
45/8 47/15 48/15
49/12 50/12 53/10
57/24 58/5 59/10 73/5)
75/5 81/10 96/25
97/13 98/16 101/15
103/3 103/21 103/25
104/14 104/18 105/5
107/4 107/8
Mr Pheasant [1] 77/9
Mr Rodric [2] 71/8
86/4
Mr Roll's [2] 2/18 3/5
Mr Rolls [1] 2/15
Mr Ron [1] 67/5
Mr Simon [1] 92/9
Mr Singh [3] 99/14
99/17 99/18
Mr Smith [2] 55/10
55/10
Mr Stein [2] 33/24
50/2
Mr Underwood [1]
64/14
Mr Warmington [2]
67/25 68/6
Mr Warmington's [2]
67/20 67/22
Mr Williams [1] 77/9
Mr Wilson [1] 99/7
Mrs [18] 57/19 58/12
76/1 76/3 76/12 76/14
77IT 77125 81/10
82/12 85/24 88/17
90/5 91/7 97/15 98/13
99/9 99/22
Mrs Misra [11] 57/19
58/12 76/1 76/3 76/12
76/14 77/7 82/12
88/17 90/5 99/9
Mrs Misra's [3] 77/25
85/24 91/7
Mrs Seema [4] 81/10
97/15 98/13 99/22
Ms [7] 35/2 49/20
89/4 89/14 96/23
96/24 108/9
Ms Dobbin [4] 35/2
96/23 96/24 108/9
Ms Stringer [1] 49/20]
Ms Vennells [2] 89/4
89/14
much [18] 1/7 1/20
6/11 15/5 29/8 30/11
32/25 35/5 35/13 52/2
65/17 67/8 76/3 91/4
105/13 107/8 107/15
107/16
must [11] 45/7 51/3
51/18 53/25 54/3
63/13 63/14 71/18
72/19 88/6 96/14
mustn't [1] 72/9
mutually [1] 48/11
my [61] 6/17 6/25
9/24 9/24 9/24 15/10
16/1 20/18 26/17 33/1
36/9 36/16 36/17 37/2
39/2 39/18 39/22
41/23 45/7 45/13
47/13 48/15 48/21
48/25 49/13 49/14
50/22 50/23 50/23
51/15 52/12 55/5
55/16 55/24 60/17
67/24 68/19 70/8
71/11 73/17 74/7
75/21 77/5 78/24 79/1
79/10 81/14 83/25
85/10 91/17 95/7 97/2
97/4 98/6 99/2 101/1
102/1 103/22 104/13
105/11 107/2
myself [1] 43/11
N
name [6] 41/11 43/4
60/12 75/17 76/12
97/2
namely [1] 91/20
names [1] 41/7
narrow [1] 78/5
nations [1] 32/1
natural [2] 6/8 61/17
nature [2] 11/6 101/1
NDA [1] 20/8
near [1] 22/9
nearly [2] 42/15 61/6
necessarily [1] 75/14
necessary [2] 31/12
84/17
need [35] 4/7 5/19
5/21 11/20 12/24 14/1
14/4 14/10 14/10
15/21 23/21 28/3
30/19 40/20 41/15
44/7 48/3 50/1 52/5
58/23 62/12 62/17
69/23 72/12 75/14
76/18 83/12 84/24
85/17 87/25 89/1 92/2
95/20 105/14 106/21
needed [5] 68/3
68/22 101/6 101/8
102/4
needs [6] 30/15
66/13 67/12 68/10
68/15 72/19
negative [3] 60/5
60/20 70/9
neither [2] 96/7 96/8
network [2] 8/2 60/16
neutrality [1] 65/18
never [9] 16/7 16/22
18/1 33/22 37/2 38/6
74/19 85/24 98/12
nevertheless [4]
61/13 65/10 95/6
103/11
new [3] 37/18 52/14
68/8
next [4] 14/12 49/6
59/24 67/1
nine [1] 39/13
no [79] 2/9 4/19 9/13
9/14 10/5 10/11 11/17)
13/9 18/15 19/18
24/19 28/1 29/4 31/14
33/11 35/4 41/7 42/3
46/6 46/12 47/17
47/20 48/10 51/24
52/5 56/10 56/11
56/25 57/1 57/3 57/4
57/8 57/10 57/12
57/13 57/17 57/23
57/23 58/5 58/16
58/16 60/3 60/11
60/18 62/3 62/12 64/4
65/14 68/13 69/3 69/5
69/19 69/23 72/2 72/3,
TAI5 74/17 75/12
75/21 78/2 80/12 82/3
83/7 83/12 84/25 85/4
85/10 87/18 87/25
89/1 89/14 89/15
89/17 92/2 93/13
96/19 97/9 98/6
103/22
Nobody [1] 6/17
non [3] 20/8 30/24
90/19
non-disclosure [1]
90/19
non-identified [1]
30/24
none [2] 93/21 94/13
normally [2] 28/18
29/16
Northern [5] 31/24
32/4 32/10 32/11
32/14
not [112]
note [15] 8/11 21/9
21/11 30/9 30/10 31/6
40/9 56/9 56/10 61/5
61/7 61/13 76/14
78/14 78/22
notebooks [1] 55/24
notes [20] 19/4 19/6
19/15 21/25 22/4
26/19 29/13 31/4 55/1
55/6 55/11 55/15
55/17 55/22 56/2
56/11 56/22 97/14
97/19 99/8
notetaker [2] 55/13
56/6
nothing [3] 4/19
92/25 95/13
notice [1] 98/25
notifying [1] 79/8
November [1] 13/17
now [65] 1/16 2/16
4/17 4/18 4/19 6/19
10/24 13/17 14/7
15/14 16/6 18/6 19/3
27/21 28/24 29/16
31/11 32/18 33/2 33/9
33/19 34/23 36/9
36/11 36/15 39/18
39/23 42/12 43/18
45/7 49/14 49/17 53/3)
54/25 58/22 60/9 62/7I
63/11 64/4 66/7 67/16)
67/24 72/8 75/16
76/16 77/7 77/24 79/2
79/20 80/20 81/4
81/14 88/10 89/12
90/4 92/8 92/19 92/21
93/14 94/16 95/2 98/2I
98/20 101/24 107/12
nuclear [1] 19/22
number [12] 7/3 24/3
37/21 39/18 53/1 61/1
63/13 63/19 63/20
97/25 99/16 107/10
number 1 [1] 39/18
number 5 [1] 7/3
numbers [1] 1/15
numerous [1] 83/18
nutshell [1] 61/21
fe)
O'Neill [1] 23/23
objections [1] 76/10
objectives [3] 14/16
14/17 16/1
obligation [2] 24/19
87/11
obligations [2] 9/25
83/20
observation [1]
65/14
observer [1] 96/7
observing [1] 56/8
obtain [3] 28/14
48/18 66/19
obvious [3] 82/14
85/23 94/6
obviously [5] 50/15
56/12 62/5 63/8
103/23
October [5] 2/1 11/1
62/13 88/16 88/25
odd [2] 58/18 58/19
off [10] 1/22 25/13
27/14 27/22 29/9
30/18 33/17 72/17
83/23 84/10
offer [2] 45/23 47/17
offered [2] 3/16 25/4
offering [1] 62/24
offers [6] 46/19
46/20 46/22 47/1 47/7
47/11
Office [118]
Office's [16] 7/21 8/5
18/7 22/25 31/25 39/5)
42/1 47/22 47/24
48/24 49/19 71/22
84/23 90/8 102/12
(39) Mr Altman's - Office's
[e)
Office's... [1] 102/16
officer [2] 22/11
24/10
offing [1] 88/15
often [1] 56/5
Oh [2] 35/3 83/17
Okay [2] 32/25 77/7
old [1] 55/24
Oliver [2] 58/25 59/7
omission [2] 83/5
83/15
omissions [2] 83/12
83/13
omit [2] 77/19 93/2
on [173]
one [36] 2/5 2/15
11/18 13/25 15/1 17/9}
18/21 33/5 34/16
39/10 39/21 40/9
45/15 49/5 58/20
60/14 64/22 65/15
67/1 71/22 73/21
74/12 75/13 75/15
79/6 84/25 87/3 87/14,
88/6 89/3 89/6 89/23
91/6 95/2 97/16 99/7
one's [3] 9/8 9/9
10/17
onerous [1] 15/5
ones [2] 56/23 59/20
Online [4] 27/15
27/16 27/23 27/24
only [14] 1/8 25/6
26/13 41/2 73/21 81/2
87/3 88/6 90/7 95/11
98/6 100/10 105/18
105/21
onto [1] 10/21
onwards [1] 14/14
open [8] 51/12 51/13
51/14 51/15 60/5
63/12 63/20 102/20
opened [2] 102/11
102/15
operated [2] 32/6
62/4
operating [4] 7/21
24/9 62/11 104/6
opine [1] 70/18
opinion [3] 70/7 95/7
103/12
opponent [3] 9/8
9/10 10/17
opposed [2] 16/24
86/25
opposing [1] 10/9
opposite [1] 69/13
option [6] 7/10 8/22
8/22 8/23 15/24 17/9
options [4] 6/22 7/2
9/12 17/11
or [71] 5/11 6/10 6/25)
9/2 9/4 9/8 9/19 10/4
12/10 13/5 15/16
18/21 20/19 23/16
26/3 26/5 32/2 32/4
32/11 34/16 38/12
38/25 39/7 40/22 42/9)
43/20 44/12 46/6 49/1
53/10 55/25 56/8 61/2
61/13 64/23 66/25
68/7 69/10 70/1 70/20
71/21 75/9 75/12
76/20 77/21 80/24
81/5 81/24 82/8 86/7
86/13 87/23 92/10
93/17 97/21 99/6
99/12 99/15 99/21
99/25 100/6 100/21
100/24 101/16 103/14)
103/16 103/17 104/1
104/24 105/16 106/9
oral [3] 82/11 88/7
92/10
orally [2] 83/18 87/3
order [9] 7/23 24/4
24/12 28/16 33/6 34/1
34/3 48/17 80/15
ordering [1] 95/22
ordinary [2] 9/20
47/4
original [5] 29/11
39/25 43/1 44/1 90/2
other [16] 8/7 10/13
23/15 29/4 40/23 46/3
56/16 57/4 65/9 75/7
75/10 75/13 93/18
94/10 95/23 98/18
others [12] 11/12
15/19 35/18 37/4 37/5)
37/13 59/10 59/11
63/17 65/14 73/18
105/16
otherwise [1] 26/25
ought [8] 50/16 88/18)
90/22 91/7 100/19
100/22 101/22 102/6
our [25] 2/15 3/18 4/1
12/18 14/5 15/5 24/4
24/16 33/9 34/23
35/17 37/11 38/22
40/13 45/14 45/15
46/19 46/20 49/2 49/5)
66/16 72/18 81/3
102/2 105/13
ours [1] 49/20
out [34] 5/19 7/1 7/5
8/19 10/11 13/22
16/18 17/10 17/11
28/2 36/1 40/1 40/7
41/17 43/5 45/3 48/8
50/1 51/10 52/19 54/2
56/1 57/4 63/24 69/11
69/15 70/6 70/12
91/13 95/6 95/16
97/20 102/5 103/15
output [2] 68/6 69/20
outset [2] 78/9 97/7
outside [1] 32/16
over [13] 5/13 7/20
11/13 13/5 14/12 22/9}
27/10 29/1 29/19
30/12 100/17 103/10
107/10
overall [1] 11/14
overarching [1] 10/7
overcome [1] 31/11
overseen [1] 7/23
oversight [1] 19/23
overturned [2] 73/13
79/16
own [4] 30/9 46/8
85/17 95/16
owned [1] 9/18
owners [1] 30/21
Po
pace [1] 13/11
pack [1] 95/6
page [50] 4/20 5/13
5/14 5/23 7/1 8/18
8/19 11/13 14/12
15/18 17/15 17/16
22/9 22/10 23/19
23/20 25/8 27/10
27/11 27/18 27/20
28/6 28/17 28/24 29/1
29/6 29/7 29/8 29/10
29/14 30/12 31/6 36/2I
37/9 37/15 45/2 62/19
62/20 67/7 72/16
79/11 79/17 79/19
79/20 86/8 92/3 92/12
93/8 93/15 94/14
page 110 [1] 92/12
page 111 [1] 36/2
page 14 [2] 62/19
62/20
page 172 [1] 17/15
page 2 [9] 23/19
23/20 29/6 29/10 37/9
37/15 67/7 72/16
79/11
page 204 [2] 8/18
8/19
page 3 [4] 28/6 29/14
93/8 94/14
page 4 [3] 4/20 27/18
79/17
page 5 [2] 15/18
79/19
page 54 [1] 92/3
page 6 [3] 27/20
28/17 79/20
Pandora's [1] 40/16
Panorama [2] 2/10
35/23
paper [3] 8/23 11/5
56/3
papers [2] 22/15
22/21
paradoxically [1]
88/4
paragraph [27] 17/15
23/21 27/12 27/20
28/19 37/25 37/25
38/1 38/7 44/8 44/18
45/1 48/3 67/9 72/23
72/24 79/12 79/17
79/19 80/21 86/9
87/10 92/8 92/11
92/22 92/23 94/22
paragraph 149.2 [2]
44/8 44/18
paragraph 15 [1]
72/24
paragraph 157 [1]
48/3
paragraph 183 [3]
92/8 92/11 94/22
Paragraph 19 [1]
79/17
paragraph 20 [1]
79/19
paragraph 24 [1]
72/23
paragraph 253.3 [1]
45/1
paragraph 433 [1]
23/21
paragraph 53 [1]
38/7
paragraph 8 [1]
79/12
paragraph 87 [1]
80/21
paragraphs [4] 8/19
19/10 21/8 79/20
paragraphs 30 [1]
79/20
parcel [3] 9/10 9/17
80/25
Parker [6] 2/15 3/5
3/21 4/11 4/12 6/7
Parliament [1] 24/11
PARSONS [37] 1/3
1/8 3/2 33/19 35/14
36/4 36/23 37/10 39/2
43/11 43/18 44/19
45/8 47/15 48/15
49/12 50/12 53/10
57/24 58/5 59/10 73/5
75/5 81/10 96/25
97/13 98/16 101/15
103/3 103/21 103/25
104/14 104/18 105/5
107/4 107/8 108/1
part [14] 9/10 9/16
39/20 45/3 48/7 48/24)
50/23 60/14 60/15
61/20 61/23 67/4
80/25 92/24
partially [1] 12/13
Participants [1]
35/15
participating [1]
76/11
particular [10] 3/11
10/4 10/8 30/9 32/3
59/19 77/2 85/1 86/10}
93/18
particularly [3] 7/7
21/1 77/8
parties [4] 46/15 47/4I
47/10 52/16
partner [11] 3/2
55/11 56/16 56/19
57/13 65/2 71/24
71/24 71/25 72/1 72/3}
partnership [1] 56/18)
party [4] 3/17 9/18
10/15 12/13
pass [1] 43/6
passed [1] 76/4
passing [1] 41/12
past [2] 79/15 84/2
Patrick [2] 25/11
64/15
PAUL [2] 1/3 108/1
Paula [3] 25/4 46/21
51/18
pausing [1] 9/16
payments [2] 90/21
91/5
payout [1] 12/20
penultimate [3]
26/17 27/12 67/9
people [10] 30/15
36/1 40/24 56/16 60/4
61/1 61/9 68/20 76/14I
107/10
per [2] 21/25 78/5
perfectly [1] 51/17
performance [1]
46/11
perhaps [5] 19/9
20/23 55/3 60/23 89/8I
period [2] 22/3 66/3
Perkins [1] 89/4
permit [1] 93/25
person [7] 5/11
44/11 54/23 56/5 77/3)
104/14 106/23
personal [3] 41/3
61/12 64/8
personally [3] 21/4
44/12 49/22
perspective [3]
39/18 43/9 43/10
persuade [1] 5/9
Peter [4] 45/15
phase [2] 52/12
52/13
Pheasant [1] 77/9
phone [1] 25/13
phrase [3] 16/15
101/25 102/11
picking [1] 31/8
(40) Office's... - picking
P
picture [1] 85/9
piece [3] 7/17 9/20
19/17
pieces [1] 39/9
pin [3] 63/24 84/8
84/9
pinned [2] 77/11
78/10
place [3] 10/9 29/17
53/6
plan [3] 14/1 15/22
34/2
planning [1] 14/15
plead [1] 61/3
pleaded [1] 80/8
please [60] 1/11 1/24
1/25 3/23 4/16 4/21
5/23 6/20 7/1 8/18
10/22 11/13 13/16
14/12 15/18 17/13
19/1 19/2 19/8 22/9
23/18 23/19 25/11
26/19 27/10 27/12
28/6 28/22 28/24
29/11 30/8 30/12
37/16 41/15 53/4
56/22 58/22 60/9
64/25 66/7 66/10
66/11 66/25 67/3 67/3
67/19 71/7 72/15
74/12 75/16 77/24
78/18 79/12 79/17
79/20 86/7 87/8 89/9
89/9 92/19
plus [1] 12/6
pm [2] 75/2 107/17
pockets [1] 7/16
point [42] 2/23 10/11
10/20 12/23 13/1
13/24 15/13 15/15
16/8 16/25 18/5 20/21
35/21 38/1 38/2 38/18
42/13 43/5 44/3 50/7
51/22 52/13 56/25
58/21 59/12 59/24
61/5 63/8 63/9 65/20
68/9 70/6 70/12 79/6
81/4 93/18 95/24 96/3
98/21 103/13 105/22
105/24
points [6] 10/16
16/16 40/19 68/11
103/12 105/18
POL [7] 44/11 45/5
48/7 48/7 48/10 48/12)
66/2
POL00006379 [1]
6/21
POL00006380 [1]
10/22
POL00006484 [1]
59/3
POL00006803 [1]
92/3
POL00021686 [1]
64/11
POL000219914 [1]
58/25
POL00021996 [1]
86/6
POL00021998 [1]
31/5
POL00022002 [1]
62/19
POL00029707 [1]
92/19
POL00040025 [1]
88/1
POL00040026 [1]
87/5
POL00041770 [1]
23/19
POL00111290 [1]
13/16
POL00111625 [1]
78/18
POL00123004 [2]
84/24 89/8
POL00129392 [1]
37/8
POL00139866 [1]
30/8
POL00297951 [1]
TAIT
POL00298123 [1]
72/16
POL00333855 [1]
26/19
POL00333856 [1]
28/23
POL00372551 [1]
89/4
POL00413924 [1]
66/7
policy [2] 61/20
61/23
political [1] 71/13
posed [1] 107/10
position [18] 12/9
13/5 32/10 47/2 47/22
47/25 52/1 58/14
63/22 66/18 71/22
85/4 103/25 104/18
106/1 106/9 106/13
106/23
positioning [1] 70/10
positive [3] 2/16
14/10 28/1
possibility [6] 15/23
51/12 51/13 51/14
79/25 88/8
possible [10] 12/15
13/23 24/14 24/18
33/9 34/10 51/21 52/4
81/9 81/12
possibly [1] 42/19
post [135]
postmasters [1] 8/3
postmasters' [1]
35/25
potential [6] 38/12
69/8 73/20 92/6 92/14
101/17
potentially [6] 13/11
14/17 38/15 87/17
91/21 106/8
power [2] 12/16 20/3
practicality [1] 23/5
practically [1] 12/7
practice [5] 8/13
16/21 29/20 45/8 56/4]
practices [1] 7/22
pre [2] 28/2 59/22
pre-1 January [1]
28/2
pre-2010 [1] 59/22
predict [1] 63/24
predominant [1]
10/16
prefer [1] 74/19
preferably [1] 34/16
preferred [1] 38/22
preparation [1] 29/22
prepare [2] 59/15
80/24
prepared [6] 7/17
22/4 27/4 29/24 97/14
98/10
preparing [4] 35/10
45/17 80/15 80/25
present [1] 18/11
presentation [3]
62/14 93/4 95/8
presented [1] 45/17
presently [1] 8/1
preserved [1] 56/24
pressure [10] 7/11
9/3 9/6 9/8 9/9 10/2
10/9 10/21 15/11
71/15
Presumably [1]
56/17
presume [2] 13/23
89/17
previous [1] 105/8
previously [5] 4/3
28/10 93/12 94/12
104/24
Primarily [1] 53/16
primary [2] 11/11
39/22
Prime [2] 19/4 19/6
principle [2] 12/21
75/9
principles [1] 75/10
Prior [2] 27/15 27/23
private [3] 32/9 70/19]
71/20
privilege [6] 21/3
21/6 23/9 26/12 26/16
82/16
privileged [2] 21/2
26/9
proactive [2] 19/16
70/3
probably [7] 12/4
13/8 13/18 58/19
65/19 81/3 98/19
problem [17] 30/14
33/11 34/13 35/4
39/24 44/1 53/17
59/22 60/1 62/4 63/18
80/22 81/20 81/23
89/16 89/18 106/24
problems [9] 7/23
53/21 87/16 91/25
93/9 93/13 94/10
94/15 95/20
Procedure [1] 83/21
proceed [1] 17/8
proceeded [1] 17/7
proceedings [9]
12/15 77/13 98/20
99/25 103/1 103/7
103/9 103/19 105/7
process [16] 4/2 4/5
7/5 7124 11/6 11/23
27/4 28/19 36/19 45/6
73/2 73/8 76/6 85/14
85/15 107/1
procurement [1]
19/22
produced [4] 6/22
6/24 11/10 45/18
product [1] 65/23
profession [1] 54/4
professional [1] 9/25
programme [2] 2/10
35/23
progress [5] 14/19
21/24 24/14 24/20
25/23
prompt [2] 57/18
90/6
pronounced [1] 87/5
proof [2] 62/24 63/1
proper [3] 9/11 30/16
73/22
properly [5] 21/6
24/12 25/22 34/2 45/6
proposal [2] 14/5
59/14
proposals [1] 8/13
proposed [1] 41/19
proposition [1] 77/1
prosecuting [1]
102/22
prosecution [15]
37/21 38/7 39/19 69/1
79/22 80/2 80/18 86/7
86/13 86/17 86/19
86/24 86/25 87/8
87/14
prosecutions [19]
32/9 39/5 62/10 66/9
66/24 67/13 67/20
68/1 68/16 68/21
79/15 84/23 86/8 87/9
89/23 100/14 101/18
102/16 102/19
prosecutor [1] 99/15
prosecutors [1] 99/7
prospect [1] 52/8
prospective [1]
69/12
protect [1] 19/19
protocol [6] 22/1
23/24 24/1 24/19
26/16 30/20
prove [1] 40/20
proved [1] 80/11
provenance [1] 79/2
provide [5] 24/7
24/15 24/16 26/14
66/17
provided [12] 23/14
26/11 26/15 61/7
78/21 81/2 81/11
85/16 85/18 91/11
98/6 99/22
providing [3] 23/3
23/5 103/18
provision [1] 91/20
public [3] 19/20 37/1
70/20
publication [1] 71/16
pull [2] 12/16 13/2
pure [1] 10/15
purely [1] 10/5
purpose [4] 10/16
68/13 69/19 79/7
pursue [4] 7/8 12/1
28/16 60/7
pursuing [2] 8/9 9/8
push [1] 5/9
pushing [1] 20/23
put [25] 5/2 6/16 7/22)
9/5 14/4 28/15 28/18
29/5 31/12 33/6 41/10
47/11 47/24 48/3 58/9)
59/3 61/21 63/21
76/21 77/1 79/5 86/17
102/20 104/19 105/3
puts [4] 106/18
putting [5] 93/5 97/9
106/1 106/9 106/13
Qo
Qc [1] 30/24
qualifies [1] 89/24
quarter [1] 91/18
query [1] 84/16
question [21] 20/6
35/21 35/24 36/9
37/22 38/10 39/2
41/23 42/25 43/10
45/7 48/15 57/13 61/8
71/20 78/12 95/9
(41) picture - question
Qu
question... [4] 97/16
100/2 101/19 102/18
Questioned [8] 1/4
35/12 50/11 96/24
108/3 108/5 108/7
108/9
questioners [1] 33/3
questioning [3]
33/13 50/7 50/8
questions [24] 1/22
33/1 33/20 35/2 35/14
41/9 45/13 48/25 50/2
50/4 58/7 64/18 98/1
98/16 99/12 99/19
101/13 102/11 102/15
102/21 106/15 106/16}
106/17 107/9
quit [1] 14/22
quit/settle [1] 14/22
quite [13] 19/20
22/19 29/18 42/19
45/23 49/11 53/4
53/25 69/22 70/10
78/18 97/25 105/22
quotation [1] 93/16
quote [1] 92/12
R
raise [2] 14/8 51/16
raised [4] 22/7 76/13
89/19 90/3
range [5] 9/12 17/10
61/11 61/19 64/3
rapid [1] 45/2
rather [7] 12/20 22/5
23/8 55/3 57/8 67/24
84/9
rationale [2] 91/19
100/24
re [1] 77/20
re-reviewed [1]
77/20
reach [2] 47/5 80/9
reached [1] 53/2
read [17] 11/16 19/8
21/8 41/5 41/17 42/14
45/1 45/3 53/22 78/11
80/24 81/23 81/25
86/9 91/24 98/6 98/14,
reading [6] 39/22
42/12 80/14 86/22
86/23 86/24
ready [2] 35/9 75/3
real [3] 93/6 93/24
94/17
realise [1] 80/15
realised [1] 96/14
reality [1] 106/2
really [7] 14/7 53/8
54/18 57/9 59/9
105/21 105/24
reason [9] 10/7 76/7
92/13 93/6 93/24
94/18 95/17 100/24
105/9
reasonable [5] 9/7
12/10 16/19 80/11
80/17
reasons [3] 7/13
10/20 14/8
reassurance [1] 83/8
rebut [1] 3/5
recall [73] 3/11 3/16
3/20 4/10 4/12 18/18
18/18 18/19 18/21
20/21 21/11 21/12
21/20 21/22 22/3 22/7)
22/7 23/2 23/11 23/13
23/16 27/5 29/22 30/2
30/4 30/5 31/18 31/20
31/21 31/22 31/22
32/18 32/21 32/22
32/24 44/11 53/7 53/7,
53/9 53/12 55/6 55/15)
57/7 57/16 57/22 61/7,
65/11 66/1 70/13
70/21 71/3 72/8 72/10
73/24 76/2 76/4 76/9
76/16 76/17 79/2 81/5
83/1 83/25 84/11 85/3)
85/10 94/2 94/24 98/2
99/17 99/18 100/17
103/20
receipts [2] 90/21
91/5
receive [3] 3/7 3/15
88/17
received [4] 48/1
66/4 80/22 89/13
receiving [1] 89/17
recipients [1] 90/1
recognise [5] 24/3
48/20 49/23 55/7
7119
recognised [1] 54/15
recollect [3] 97/6
97/8 99/1
recollection [14]
18/14 18/15 20/16
20/18 55/5 56/10
56/11 57/1 57/11
57/12 60/17 67/24
83/25 103/22
recommend [5] 9/13
10/12 11/8 38/24 95/9)
recommendation [2]
7/10 8/6
recommendations
[1] 72/23
recommended [5]
7/10 8/24 12/2 62/24
100/12
recommending [1]
10/8
reconsidered [1]
66/15
record [1] 58/24
records [2] 62/23
80/6
redacted [5] 41/2
41/7 41/11 43/4 75/22
redaction [1] 75/17
redactions [2] 41/3
94/25
reduce [1] 24/17
refer [4] 44/6 88/6
95/3 97/23
reference [25] 1/15
2/16 3/14 44/16 48/4
64/6 70/16 70/25 71/3
72/13 77/16 78/23
78/24 79/4 79/5 79/9
79/10 81/3 86/15
86/21 88/1 90/16 92/2
92/5 93/16
references [4] 37/19
78/4 78/8 78/13
referencing [1] 40/14
referred [5] 78/7
78/16 91/15 93/14
97/18
referring [10] 4/14
21/12 30/25 41/25
42/6 42/17 42/18
83/15 87/19 87/21
refers [3] 13/2 19/24
30/24
refining [1] 4/6
reflect [2] 17/22
75/11
reflected [1] 43/15
reflection [1] 63/11
reflections [1] 25/20
reflects [1] 61/13
refusing [2] 45/5
45/23
regard [1] 37/2
regarding [2] 6/1
7119
regardless [2] 12/22
93/10
regards [1] 32/2
regret [1] 49/1
regroup [1] 5/21
reinvestigate [1]
48/22
relate [2] 31/9 92/8
related [4] 100/2
101/17 103/1 103/9
relating [5] 21/19
24/24 25/16 95/10
99/8
relation [15] 19/17
22/22 23/11 27/14
27/22 28/10 29/9
67/13 68/16 75/17
83/22 85/7 88/22
90/20 100/13
relationship [1] 18/7
relevant [7] 39/20
66/24 68/1 68/21
77/14 77/17 87/17
reliable [5] 50/25
51/11 62/2 63/7 91/1
relied [3] 57/25 58/10}
77/1
reluctance [1] 6/8
reluctant [1] 6/14
rely [1] 105/14
remained [1] 65/10
remains [1] 95/10
remedy [1] 62/25
remember [13] 25/16
25/18 27/6 32/9 57/5
62/7 62/13 66/3 70/3
70/5 70/6 92/17 92/20
remembered [1]
12/11
remit [2] 32/12 78/5
remote [3] 40/19
90/18 90/20
remotely [1] 35/18
reopened [1] 79/16
repeat [2] 43/11
83/12
report [36] 24/20
24/23 37/19 37/20
37/23 38/4 38/14
38/19 38/23 38/25
39/9 39/14 39/16
39/20 40/3 40/5 40/16
41/2 41/5 43/3 59/15
59/25 73/3 73/8 75/19)
84/21 85/5 91/20 92/5
92/14 92/25 93/7
93/17 93/19 94/4 95/9)
reported [1] 59/13
reporting [1] 7/25
reports [2] 24/17
38/24
represent [3] 44/11
ATIT 97/2
representative [1]
24/5
representatives [3]
45/25 46/5 47/16
represented [1]
35/16
representing [1]
40/24
represents [1] 14/1
reputation [1] 83/23
reputations [1] 43/23
request [2] 66/13
66/16
requested [1] 23/4
requests [2] 66/5
102/3
required [1] 36/21
requirements [1]
24/16
requires [1] 24/13
resist [3] 84/22 85/5
89/22
resolution [1] 17/19
resolve [3] 52/4 60/1
90/21
resolved [1] 31/3
resources [1] 15/3
respect [2] 26/14
60/25
respectability [1]
85/21
respond [3] 3/10
68/2 72/22
responding [1] 39/1
response [9] 5/14
5/22 41/16 59/16
67/10 72/6 72/7 72/9
84/4
responsibilities [1]
30/21
responsibility [3]
50/22 75/18 75/21
responsible [1] 80/4
rest [2] 41/4 79/1
result [3] 8/4 36/21
79/15
resulted [1] 4/4
resume [1] 33/15
retain [2] 31/1 31/15
rethink [1] 6/2
retrospectively [1]
37/21
return [2] 65/5 65/7
returned [1] 65/9
reveal [2] 91/23
95/22
revealed [3] 91/21
93/22 95/18
revelation [1] 53/19
reversal [3] 39/17
39/21 93/1
reversals [1] 40/19
reverse [1] 63/22
review [31] 21/20
39/18 39/21 53/19
58/20 59/19 62/3
65/24 70/1 70/2 71/17
72/20 73/2 73/4 73/8
73/10 74/2 82/23
83/22 84/21 84/22
85/6 85/13 89/12
89/22 89/24 91/24
92/4 93/15 96/4
100/13
reviewed [5] 66/6
77/12 77/20 85/14
97/19
revised [1] 24/16
Richard [3] 2/5 2/24
25/13
rid [2] 51/21 61/22
right [47] 7/13 20/1
29/10 29/15 29/16
33/2 34/12 34/21
40/25 43/18 44/15
48/16 52/1 53/25 56/4)
(42) question... - right
R
right... [32] 56/12
56/22 60/16 60/18
62/21 65/12 71/10
77/7 78/18 79/11
81/10 82/14 83/4 84/4,
84/20 86/16 94/10
94/16 95/2 96/2 98/4
98/8 98/10 98/16
98/19 101/15 102/5
102/24 103/13 103/25
107/7 107/15
right-hand [4] 7/13
29/10 29/15 29/16
rise [4] 36/25 52/14
73/19 74/7
risk [2] 51/21 59/16
risks [6] 63/2 70/7
70/9 79/5 86/4 86/7
robust [3] 42/2 42/3
63/6
Rod [4] 25/2 25/15
30/17 55/5
Rodric [13] 16/13
17/3 18/8 23/24 26/8
31/7 55/4 64/14 64/15}
71/8 86/4 87/22 88/2
role [7] 24/12 84/18
99/15 101/2 102/2
105/23 105/23
roles [1] 30/20
Roll's [3] 2/18 2/25
3/5
rollout [4] 27/15
27/16 27/23 27/24
Rolls [2] 2/5 2/15
Ron [6] 64/21 67/5
67/10 67/11 68/9
69/20
room [6] 53/8 54/23
56/5 56/16 56/19
96/18
Rose [21] 37/19
37/20 38/4 38/14
38/19 38/23 38/25
39/8 39/14 39/16 40/3,
40/16 41/1 43/3 75/19)
91/20 92/5 92/14
92/25 93/17 94/4
rottenness [1] 85/6
round [1] 25/6
Row [2] 53/6 53/8
Royal [1] 51/20
Rule [1] 83/21
Rule 19 [1] 83/21
Rules [1] 83/21
running [2] 68/11
69/18
ruthless [1] 50/18
s
safekeeping [1] 65/6
safety [1] 70/18
said [27] 3/8 4/17
15/10 16/6 18/10
30/20 31/10 41/12
45/22 45/24 54/5
59/13 62/11 63/16
67/25 68/14 69/17
74/9 78/9 80/20 82/8
83/18 87/6 90/1 93/15
101/4 106/11
sake [1] 58/24
Sally [1] 49/5
same [14] 4/20 27/20
29/14 32/6 35/21
39/10 52/1 64/23 79/4
87/7 89/14 91/10
91/12 96/2
sanitised [1] 56/24
sat [2] 19/25 20/15
satisfied [2] 80/10
80/17
save [1] 44/23
saw [10] 2/20 9/20
11/15 22/20 26/3
29/12 35/22 69/22
70/17 84/18
say [50] 5/15 8/21
9/16 13/18 15/9 15/19
16/3 17/24 23/9 29/4
33/19 36/16 37/17
38/9 38/13 40/18 43/9
43/25 44/9 45/4 45/18
46/4 47/12 49/18
51/24 52/5 52/7 52/18
53/21 54/6 55/23
63/12 64/12 65/21
67/5 68/10 68/14
71/24 72/4 72/10 74/1
74/15 75/18 81/1
84/17 86/1 88/21 94/7,
102/1 105/1
saying [14] 12/24
20/20 54/18 56/10
57/10 57/15 57/23
63/5 70/17 75/8 76/16
81/8 95/4 104/13
says [39] 2/2 4/22 7/4
7/9 10/25 13/20 16/14)
17/117 19/13 20/5
22/10 22/14 23/25
25/1 25/12 27/13
27/21 30/13 30/23
31/2 31/6 40/8 40/11
40/13 41/17 42/7
45/16 45/21 48/5 49/7
57/21 57/22 66/2
67/13 68/11 68/16
80/17 88/12 97/22
scandal [1] 37/1
scheme [19] 28/12
28/14 32/17 39/19
43/9 43/10 44/5 48/6
48/12 48/17 48/21
51/15 51/17 52/2
52/11 52/20 65/4
65/12 76/11
scope [1] 101/5
Scotland [5] 31/24
32/4 32/9 32/11 32/14]
Scottish [2] 32/19
32/23
screen [9] 1/12 1/16
28/22 44/20 44/21
48/4 62/18 89/1 89/9
screens [1] 37/11
scribbling [1] 55/4
scroll [34] 5/13 5/22
11/13 13/17 14/12
16/17 17/9 17/16 19/9
21/23 22/9 24/25 25/8
25/10 26/21 28/25
30/12 37/9 40/10
41/15 64/11 64/12
64/12 64/19 64/25
66/10 66/11 66/25
66/25 89/9 89/10
89/10 89/11 92/21
scrolling [3] 29/1
38/20 67/3
scrutinising [1]
67/19
scrutiny [2] 67/14
68/17
second [31] 23/19
27/11 39/16 53/18
59/12 62/2 64/7 64/17
64/17 65/3 65/4 65/16
65/24 66/8 66/14
66/15 66/19 66/22
67/17 68/24 69/6
71/16 73/3 73/7 82/23)
83/22 86/8 86/9 87/9
91/11 102/18
Secretary [1] 24/5
section [7] 11/13
28/8 29/9 30/1 30/13
86/7 87/8
sections [1] 11/16
secure [1] 14/21
see [64] 1/5 1/16 2/8
2/11 2/18 2/21 5/13
7/13 9/12 14/17 16/18
25/4 25/11 26/21
27/11 27/18 27/20
28/7 28/17 29/1 29/5
29/11 29/14 30/12
34/10 34/21 35/9 38/7
43/24 43/25 44/21
45/20 48/13 51/3 52/2
54/13 54/19 58/6 60/4
62/18 64/19 64/25
66/7 67/6 77/20 78/14
86/11 86/17 86/20
92/23 95/8 95/12
96/25 97/12 97/20
102/14 103/3 106/1
106/6 106/8 106/12
106/17 106/19 106/24]
seek [3] 12/10 28/1
59/19
Seema [12] 28/11
57/14 81/10 82/25
84/25 86/21 87/19
88/7 97/15 98/13
98/14 99/22
seemed [4] 24/22
48/12 93/18 96/7
seems [13] 16/8 23/6
28/19 39/23 65/19
81/14 82/21 87/20
88/8 90/11 96/2 96/6
101/24
seen [5] 3/24 4/2
51/4 95/5 100/3
send [1] 47/15
sending [2] 19/6 26/3
senior [4] 55/3 55/12
56/5 56/17
sensible [3] 41/20
42/8 89/20
sent [8] 37/12 43/14
45/25 46/4 52/11
58/23 58/25 81/4
sentence [5] 13/1
28/5 74/11 86/12
92/12
sentenced [1] 80/11
separate [2] 39/9
102/25
September [7] 6/23
10/24 26/20 53/3 62/9}
76/5 100/4
sequence [1] 72/11
series [3] 12/4 70/9
75/7
serious [8] 50/15
53/17 54/10 54/11
90/13 100/6 100/21
101/19
seriously [3] 84/1
84/6 91/2
served [1] 79/7
set [11] 8/19 16/18
51/17 52/2 52/10
52/19 63/10 68/11
69/17 97/19 103/15
sets [3] 7/1 17/10
17/114
setting [3] 10/11
13/22 15/19
settle [11] 14/22 46/1
46/6 46/9 46/10 46/13)
ATINT 47/21 48/24
52/15 52/17
settled [1] 17/6
settlement [2] 12/11
47/6
settlements [1] 53/1
settling [4] 52/8
several [2] 18/4
106/25
shadow [1] 2/8
shall [2] 25/15 41/14
sham [2] 45/10 52/20
shame [1] 55/20
shape [2] 105/20
105/21
share [4] 20/12 20/15)
26/5 26/5
shared [3] 21/19 94/5]
94/7
shareholder [1] 24/5
sharing [8] 5/7 20/7
20/24 21/1 21/1 23/25]
26/8 38/14
she [15] 6/16 19/6
19/13 23/25 25/1 49/5)
49/7 55/2 76/5 80/11
88/17 88/20 90/6
90/11 90/12
sheer [1] 23/3
ships [1] 69/10
Shoosmiths [3]
60/11 60/14 60/14
short [3] 35/7 72/5
75/1
Short-term [1] 72/5
shorter [1] 34/4
shorthand [2] 34/19
7413,
shorthand-writer [1]
34/19
shot [1] 82/4
shots [1] 14/2
should [24] 12/11
15/2 15/3 17/7 41/11
46/12 57/14 57/18
63/3 70/8 70/18 70/19
72/22 73/1 76/6 79/15}
81/11 82/16 84/13
84/13 87/12 87/12
89/8 101/25
shouldn't [3] 81/13
84/17 99/9
Shout [1] 14/6
showed [1] 48/23
shows [2] 39/3 59/8
shrapnel [1] 63/25
shredding [3] 31/15
57/1 57/1
shut [2] 69/25 70/1
sic [3] 2/6 2/16 2/22
side [20] 7/13 28/22
28/22 29/5 29/5 29/7
29/10 29/15 29/15
29/16 29/17 32/6 32/7
54/6 73/4 73/10 74/2
74/4 74/9 74/9
Sight [22] 53/18 62/2
64/7 64/17 64/17 65/3
65/4 65/16 66/8 66/14I
66/15 66/20 66/22
67/17 68/25 69/6
71/17 73/3 73/8 82/23}
83/22 91/12
Sight's [1] 65/24
sighted [4] 25/22
(43) right... - sighted
Ss
sighted... [3] 50/17
84/12 90/2
signed [3] 4/3 61/23
7217
significant [1] 8/10
signing [2] 4/6 20/7
silver [1] 11/17
similar [2] 11/14
11/25
Simon [11] 30/9
30/14 30/20 30/25
31/2 31/10 31/14
42/14 92/9 94/16
94/24
Simpkins [1] 6/1
Simpkins’ [1] 6/6
simply [1] 76/3
since [1] 34/23
Singh [10] 37/12
41/24 42/5 42/13
54/25 66/9 89/7 99/14
99/17 99/18
Singh's [1] 41/16
single [1] 86/24
singular [3] 86/21
87/18 87/20
sir [22] 1/5 33/1
33/16 34/4 34/5 34/7
34/20 35/1 35/11
35/11 50/10 60/13
74/114 74/17 74/21
74/24 75/4 86/15
96/21 96/25 107/6
107/14
sit [1] 73/1
sits [1] 49/6
sitting [1] 60/8
situation [7] 6/16
67/17 84/5 105/4
105/12 105/13 106/3
slightly [7] 16/17
17/16 21/23 26/21
27/21 40/10 81/24
slow [1] 63/3
Smith [2] 55/10
55/10
Smith's [1] 30/10
so [109]
solicitor [2] 17/2 17/2
solicitors [6] 38/15
38/17 40/17 60/16
75/5 75/11
solicitors’ [1] 60/15
solution [4] 12/8 91/6
91/6 91/6
some [44] 1/13 10/13
13/22 13/24 14/4
14/21 17/5 18/23
19/10 21/19 22/20
24/7 26/15 26/21 29/1
31/10 32/17 35/16
36/13 36/14 37/3 37/4
37/5 39/13 46/8 46/9
46/16 46/19 47/19
48/18 49/15 49/23
50/7 52/15 64/1 65/18
70/22 71/4 72/12 81/4
89/19 97/13 97/14
105/16
somebody [4] 2/1
28/15 28/20 104/5
someone [8] 5/4 6/10
55/5 101/10 105/6
106/13 106/17 106/19
something [15] 13/5
14/23 21/15 21/20
30/2 68/22 68/23
69/11 69/14 69/16
76/22 97/4 97/17
104/2 106/11
sometimes [1] 84/15
somewhere [2] 6/10
69/7
soon [1] 81/12
sorry [11] 18/21 29/6
34/8 41/1 44/16 50/19)
65/24 67/4 89/11 97/9)
102/20
sort [3] 5/11 47/8
48/18
sought [2] 82/19
103/12
sound [1] 85/14
source [3] 103/6
105/6 106/4
Sparrow [1] 62/14
speak [6] 22/6 74/23
92/16 99/11 99/14
105/1
speaking [4] 21/25
23/7 99/5 106/4
specific [4] 28/4 76/2
76/13 97/18
specifically [9] 3/16
3/20 27/6 30/4 67/21
73/15 74/10 78/4
97/16
speed [1] 77/25
spellings [1] 1/14
spend [1] 22/12
spent [1] 45/16
SPMs [1] 60/6
spoke [3] 94/24
99/17 103/11
spoken [6] 37/18
40/11 43/15 45/14
46/3 106/11
spot [5] 39/18 39/21
73/2 73/8 106/18
spotlight [1] 7/22
Square [1] 98/1
SS [1] 66/2
stab [4] 72/14
stage [8] 2/3 8/6 9/13
9/14 10/5 24/23 32/20
43/5
standards [1] 50/16
start [13] 4/20 8/2
17/11 23/19 26/19
28/23 31/11 34/24
35/25 51/8 60/7 74/22
78/21
started [1] 74/17
starter [1] 17/11
starters [1] 4/24
starting [2] 31/8 38/3
state [4] 24/6 99/19
103/24 104/20
stated [3] 82/16
93/12 94/12
statement [32] 1/13
1/16 2/7 2/20 2/25 3/6}
4/2 413 4/7 8/17 8/17
10/24 16/6 23/21
23/22 36/16 44/7 44/8}
45/1 48/2 48/25 49/1
49/13 66/18 80/21
92/8 92/11 93/9 94/17,
103/2 105/11 107/9
statements [5] 2/4
2/18 37/22 44/6 70/9
statistics [1] 52/25
status [3] 58/2 58/12
77/4
stay [1] 41/11
steer [2] 30/19 68/24
steering [1] 6/22
Stein [2] 33/24 50/2
stenographer [2]
34/14 50/8
step [3] 10/4 10/5
36/5
steps [1] 9/5
Steve [13] 2/15 2/16
3/4 3/7 3/9 3/21 4/9
4/24 4/25 5/10 5/17
5/20 6/7
Steve's [1] 6/18
stick [2] 22/4 64/10
still [10] 24/2 30/19
33/2 46/12 46/14
47/23 61/1 65/1 66/15
103/11
stood [1] 7/2
stop [1] 107/12
strategic [2] 11/3
11/8
strategies [2] 9/8
13/14
strategy [20] 1/23
6/19 6/22 7/2 8/24
9/14 9/15 10/12 10/13}
10/15 10/18 11/3
11/14 11/15 12/1
12/23 13/4 16/7 16/9
16/16
straw [4] 14/1 15/18
16/1 16/11
strength [1] 15/5
strengthen [1] 47/2
stress [1] 5/2
stressful [1] 4/4
Stretch [1] 7/5
strike [1] 96/16
strikes [1] 102/8
Stringer [2] 49/5
49/20
strong [2] 36/14
49/11
structure [1] 20/7
struggling [3] 13/11
13/12 25/3
stung [1] 19/18
style [1] 79/2
Subcommittee [1]
22/15
subject [9] 1/15 19/4
39/17 42/22 66/2 66/4,
75/9 79/21 105/8
subpoenaed [1] 5/6
subpostmaster [2]
40/21 46/23
subpostmasters [17]
35/15 36/7 36/24
39/14 40/17 43/22
48/14 48/19 49/23
51/16 52/4 54/16
60/23 63/19 65/17
66/5 76/10
subpostmasters'’ [1]
64/3
subsequently [2]
54/17 77/12
substance [2] 69/16
82/14
substantial [2] 70/15
7115
successful [3] 73/21
90/12 90/25
such [13] 4/3 9/15
10/18 24/11 49/20
67/13 68/7 68/17
70/13 76/23 76/24
103/20 103/21
suffering [2] 49/18
49/23
suggest [11] 6/2 14/6)
50/12 56/23 59/8
61/20 70/10 75/8
88/25 91/17 103/5
suggested [2] 9/2
22/19
suggestion [1] 23/6
suggests [3] 88/14
93/8 94/14
summary [2] 8/10
10/13
summonsing [1]
5/17
supervised [2] 44/14
48/16
supervision [1]
84/19
supplier [1] 19/22
support [7] 3/7 3/19
3/20 12/14 12/17 13/3}
45/18
supported [1] 12/12
supporting [1] 4/5
suppose [1] 49/11
sure [12] 5/10 14/8
20/18 21/6 26/11 54/8
74/18 102/2 102/18
104/10 106/14 106/15)
surely [3] 57/10
57/24 76/21
surprise [1] 19/18
Susan [2] 55/2 80/23
suspect [4] 11/11
29/23 56/2 63/17
suspense [1] 98/21
suspicious [1] 21/13
swayed [1] 5/12
system [17] 9/10
9/17 40/22 50/25
50/25 51/11 51/25
58/1 58/11 59/15
61/18 62/2 63/7 85/7
87/16 91/1 91/22
systemic [1] 62/4
T
tables [2] 77/16 78/8
tactical [3] 14/21
16/2 48/18
tactically [1] 15/23
taint [1] 85/7
tainted [1] 82/23
take [25] 5/11 10/18
10/20 11/24 12/3 14/2)
15/1 19/9 33/13 34/11
42/8 44/5 50/6 54/22
55/15 56/9 69/23
73/21 74/19 84/24
86/9 87/25 90/15 92/3
103/17
taken [13] 29/19 36/9
46/13 46/17 56/2
56/25 62/17 70/4
85/24 89/2 96/3
105/24 105/24
takes [1] 10/15
taking [8] 10/5 11/22
19/16 29/20 36/5 55/1
56/10 56/11
talk [5] 13/25 14/5
37/20 46/21 104/20
talked [1] 91/4
talking [9] 10/14
34/24 35/3 36/18
41/24 75/19 76/12
89/5 91/12
talks [2] 41/21 89/15
target [3] 12/18
15/25 16/17
targeting [2] 16/19
97/16
task [4] 15/5
(44) sighted... - task
T
team [17] 2/15 5/3
5/8 5/25 6/25 10/10
13/10 14/4 16/12 17/6)
17/12 23/2 44/13 61/9
72/14 78/3 98/7
technical [2] 63/1
63/4
tell [9] 19/10 20/11
26/24 42/12 45/14
50/3 74/3 93/23
106/23
telling [3] 39/14 46/2
105/7
ten [6] 17/12 34/11
34/16 43/21 74/13
74/16
tenor [1] 30/5
term [4] 63/23 72/5
72/12 102/13
terms [9] 63/21 69/19)
70/15 70/24 71/3
72/12 90/15 98/18
104/15
test [1] 95/14
testimony [1] 84/2
than [15] 6/11 12/21
15/4 15/6 22/5 23/8
23/15 29/4 37/4 37/5
80/6 81/24 84/9 93/18
105/11
thank [33] 1/6 1/7
1/20 4/21 8/16 8/18
10/22 19/12 26/17
27/10 29/8 30/8 30/10)
32/25 33/23 35/1 35/5)
35/11 35/13 37/15
50/4 50/5 60/13 67/7
74/24 75/4 96/22
96/25 97/11 107/4
107/8 107/15 107/16
Thanks [1] 24/1
that [686]
that 1 [1] 100/2
that's [50] 8/22 17/14
17/15 18/6 25/24 26/9}
29/8 29/16 33/4 34/1
34/6 35/4 39/6 39/22
40/24 42/24 44/15
46/7 49/11 51/22
57/21 57/21 58/14
60/17 61/20 64/5 64/6
64/6 73/1 74/7 74/24
79/8 82/10 83/4 84/10)
84/21 86/21 87/24
88/12 97/22 98/20
99/2 99/2 101/9 102/8,
102/25 104/16 106/13)
106/23 107/14
theft [2] 80/9 80/16
their [26] 2/13 2/14
7/7 11/21 12/16 13/2
32/4 36/21 36/22
36/22 42/3 43/7 43/23
44/2 50/22 51/9 61/1
62/3 65/18 66/18
68/25 81/16 82/19
85/13 85/17 101/18
them [32] 23/5 33/6
36/7 40/18 44/8 46/10
49/16 49/17 49/22
52/4 55/11 63/20
65/13 66/17 71/4 71/6
72/21 78/11 83/12
84/3 87/1 87/2 90/5
91/13 95/22 95/22
96/8 100/9 105/7
106/18 106/20 106/22!
thematic [1] 12/5
themselves [2] 6/20
80/5
then [55] 5/21 7/2
7/22 9/22 15/9 16/3
19/1 19/24 23/14
30/18 30/18 30/23
31/2 31/7 35/4 37/7
37/20 38/9 38/12
38/20 41/21 45/19
46/11 52/5 53/19
54/17 55/2 55/11
63/19 63/21 63/24
65/1 66/15 66/15 67/2
67/23 68/3 69/11 72/3
72/14 72/15 72/25
74/22 79/19 85/16
88/18 89/5 91/15 93/2
98/17 98/18 100/19
101/6 102/5 103/9
there [150]
there's [13] 3/14 4/19)
5/22 11/13 28/7 34/12
52/5 57/4 62/12 87/25)
88/16 89/5 106/25
therefore [10] 12/2
12/18 16/1 17/19
50/25 51/25 56/8
79/25 94/11 95/14
these [20] 6/3 10/3
12/14 16/1 16/15
22/24 26/19 27/1
27/18 29/20 29/23
31/17 38/6 65/3 68/11
77/20 83/11 94/25
96/16 104/23
they [90] 7/2 8/14
12/9 12/20 15/7 15/11
17/8 19/18 23/13 26/4
26/5 26/10 26/10
26/15 28/14 29/24
32/6 32/7 32/8 33/5
33/8 33/8 36/1 36/6
39/12 43/4 43/4 45/11
46/4 46/22 46/25 47/1
47/13 48/8 50/24 51/11
51/12 51/13 51/14
51/15 51/25 52/1
52/13 54/17 55/20
56/7 56/9 58/1 58/3
58/11 59/7 60/2 60/2
60/8 60/10 60/11
60/12 63/5 63/7 63/13
63/15 65/9 65/16 66/5
66/23 66/23 68/3 68/4
68/20 68/21 68/22
75/6 77/3 81/13 83/13
83/14 84/3 84/4 84/6
84/8 84/25 85/16
94/22 97/14 100/20
103/16 105/8 105/9
106/11 106/12
they're [5] 43/16 56/7
60/19 106/23 106/25
they've [3] 35/20
43/7 65/12
thing [3] 40/23 89/23
97/4
things [10] 8/8 24/3
30/18 32/12 34/22
48/8 69/22 73/24 84/4
97/3
think [102] 3/18 5/7
5/21 8/19 10/23 12/7
13/7 13/8 13/14 13/18}
14/9 15/21 16/12
16/15 17/3 17/9 18/3
18/10 18/16 18/22
19/11 23/20 23/25
25/9 25/18 26/7 27/5
27/6 27/7 31/3 33/8
34/8 34/12 35/20
36/15 39/8 41/24
42/14 42/17 42/24
42/25 42/25 43/14
43/25 44/19 47/4
47/10 49/11 51/7 51/8
51/24 52/8 52/24
54/25 60/11 61/8
61/17 62/20 63/10
64/11 64/24 65/1
65/18 66/22 67/21
69/13 69/14 70/5
71/23 73/7 74/5 74/17,
74/18 74/19 75/14
77/11 78/2 78/10
78/15 86/22 86/23
87/6 87/21 92/10
96/21 97/12 97/14
97/23 97/25 98/18
98/19 98/24 98/25
100/19 101/1 101/21
102/10 103/4 104/16
105/1 105/21 106/4
thinking [7] 13/19
13/19 54/3 54/20
73/24 91/10 91/15
third [6] 3/17 7/1
12/13 13/19 14/16
38/1
this [196]
those [37] 6/9 12/25
13/2 15/1 21/7 21/8
23/11 23/17 26/3 26/3
28/13 29/13 31/3 32/5)
33/1 34/22 41/3 42/2
43/7 46/9 46/14 47/12
48/23 51/1 51/16
56/22 57/22 74/8
75/14 78/11 86/20
87/22 96/15 97/19
98/2 98/17 106/16
though [11] 16/16
20/13 21/18 23/6 24/2,
27/5 29/18 54/13
54/15 78/22 101/12
thought [12] 5/5 24/7
31/12 37/4 47/22 63/5)
63/5 68/1 79/6 85/11
94/17 105/15
thoughts [2] 13/23
25/7
thousands [1] 60/23
threat [1] 69/4
three [6] 12/15 33/3
44/12 63/9 78/8 91/6
threshold [1] 62/24
through [14] 3/17 5/2
11/23 14/5 17/9 19/10}
25/4 35/19 52/9 61/2
73/2 77/23 98/4 102/3I
throughout [2] 13/6
13/7
throwing [1] 36/7
Thus [1] 95/10
tie [1] 51/20
time [67] 3/24 5/4
7/20 8/14 11/20 13/5
13/9 14/4 15/17 16/9
20/21 22/23 29/20
30/5 36/13 36/19 44/3
44/23 46/18 49/14
49/16 52/1 53/11
53/13 54/13 54/19
56/2 56/15 56/19
58/21 59/9 62/6 62/12,
63/7 63/8 63/9 64/1
64/4 64/24 68/20
71/15 72/2 73/17
73/18 73/25 76/3
78/12 81/4 81/15
81/20 82/18 83/9
84/11 86/2 89/17
91/14 94/24 96/19
98/3 99/5 99/13 100/9
101/23 102/7 103/23
104/13 105/25
times [2] 10/19 15/6
timescales [1] 33/12
tired [4] 45/21
today [8] 1/8 1/21
3/10 5/19 35/18 36/11
78/21 80/20
together [4] 15/21
30/16 40/6 53/15
toing [1] 70/24
token [1] 46/22
told [3] 45/15 94/2
99/10
Tom [8] 18/24 18/25
19/24 19/24 20/11
20/14 22/2 22/16
too [8] 5/9 7/8 8/25
35/22 36/14 55/3
63/11 65/17
took [13] 9/5 16/6
19/6 29/25 36/10 49/4)
53/6 59/11 62/20
69/24 97/7 105/20
105/21
top [3] 5/22 5/23
17/16
topic [11] 4/10 4/20
18/6 23/18 26/18
31/24 37/7 44/4 70/21
91/18 102/25
topics [1] 1/9
Torstein [1] 105/16
touched [2] 97/5 99/4
towards [2] 6/19
14/19
trade [1] 83/23
trading [1] 82/22
training [4] 3/7 3/14
3/15 3/17
transactions [3]
39/17 39/21 62/23
transcript [3] 36/2
88/1 104/9
transcripts [7] 77/13
T7IN7 97/17 98/5
98/13 98/14 98/17
trial [22] 13/20 13/23
13/24 14/13 14/14
14/16 14/18 15/12
16/4 16/22 17/14 18/2)
18/4 91/7 91/9 91/16
97/14 98/5 98/13
98/15 99/9 99/23
trials [3] 12/5 13/9
95/23
tried [4] 5/9 55/24
70/14 74/5
tries [1] 16/1
true [2] 1/17 1/17
truth [2] 1/13 84/10
try [4] 5/10 12/8
51/20 74/12
trying [6] 16/2 54/12
65/13 66/19 99/12
101/16
Tuesday [2] 107/12
107/19
turn [21] 1/24 4/16
6/20 7/1 10/22 13/16
15/18 17/13 19/1 19/1
23/18 23/22 27/10
27/18 27/19 28/6
28/17 30/17 44/8
77124 102/11
turned [2] 4/1 45/17
(45) team - turned
T
turning [3] 15/13
15/15 45/2
two [10] 19/2 19/17
39/9 44/12 47/4 47/10
89/3 91/6 96/16 97/3
two years [1] 19/2
tying [1] 20/6
type [1] 71/12
typed [1] 55/11
U
UKGI [31] 18/7 18/20
18/21 18/22 18/23
19/16 19/25 20/3
20/11 20/11 20/16
20/22 21/1 21/2 21/14
21/18 22/1 22/5 22/17
22/23 23/1 23/12
23/14 23/23 23/25
24/22 25/21 26/1 26/6
26/9 26/10
UKGI00009458 [1]
17/14
ultimately [1] 18/1
unacceptable [1]
87/6
unattractive [1]
11/23
unaware [3] 88/22
104/7 104/10
unbearable [1] 7/12
unchanged [1] 95/7
unclear [1] 33/16
uncomfortable [1]
66/16
under [13] 2/8 7/22
15/11 16/14 36/7
58/20 58/23 59/18
67/14 68/17 71/15
76/21 84/18
underlying [2] 39/24
64/2
undermine [2] 86/25
87/2
undermined [5] 58/2
58/12 77/4 86/13
86/19
underneath [1] 85/22
understand [22] 4/13
6/3 39/8 46/16 52/3
53/5 54/6 58/14 64/5
73/3 73/7 73/9 73/11
73/12 74/1 74/2 74/3
74/10 76/20 100/5
101/1 101/16
understanding [17]
6/7 29/19 31/25 32/3
42/10 47/14 48/21
62/5 62/5 74/8 77/5
85/10 89/1 99/2
101/19 104/7 104/13
understood [10] 17/3
20/3 32/8 36/19 41/1
62/6 74/5 91/11 93/5
94/3
undertake [1] 85/17
undertaken [5] 71/12
78/2 78/3 85/13 97/13)
undertakings [1]
20/9
Underwood [1] 64/14!
undone [1] 62/11
undoubtedly [1] 15/4
unfortunate [1] 57/8
unfortunately [3] 6/1
31/17 49/22
unhappy [1] 6/16
unjust [1] 60/24
unless [1] 101/10
unreasonable [1]
10/16
unreliable [2] 82/1
91/21
unsafe [6] 73/13 74/6
82/24 89/5 89/15
95/23
unstoppable [1] 90/6
until [7] 61/6 74/23
105/13 105/19 105/24)
107/12 107/18
up [61] 1/11 5/22 7/8
7/12 8/17 13/11 15/19)
16/17 16/23 17/16
24/25 25/8 25/14
26/15 31/8 37/3 37/10
40/10 41/14 41/15
42/22 44/8 44/17
44/20 44/21 45/17
48/7 51/15 51/18
51/20 52/2 52/10
52/19 55/11 58/24
59/3 61/24 62/12
62/18 63/12 63/20
63/25 64/12 64/19
64/25 65/2 66/25
72/12 77/25 86/5 89/1
89/8 89/9 89/10 89/11
90/18 92/22 97/9
102/11 102/15 102/20)
update [2] 21/24 22/5I
updated [3] 27/19
28/17 28/21
updates [6] 22/16
22/21 23/3 23/4 24/16
24117
updating [2] 22/17
23/7
upholds [3] 75/6
75/12 81/19
upon [9] 57/25 70/11
75/9 75/11 81/22
85/20 97/5 98/9 99/4
urgent [1] 3/8
urgently [1] 5/19
us [21] 11/19 15/5
19/5 21/9 21/15 24/4
26/22 27/1 29/2 31/16
40/21 45/15 46/2 53/4
54/2 60/9 71/22 73/5
81/4 101/7 103/13
use [9] 4/7 23/6
63/23 64/18 69/9
102/10 102/12 103/17
105/5
used [10] 2/6 16/15
36/14 57/6 69/11 85/8
93/11 94/11 104/22
105/10
useful [2] 102/8
102/10
using [9] 28/13 47/1
48/12 48/16 103/5
103/8 104/1 106/19
106/22
utter [1] 52/23
Vv
value [3] 19/20 47/11
47/23
van [1] 37/12
various [1] 7/2
Vennells [3] 46/21
89/4 89/14
Vennells' [1] 51/18
verbal [3] 22/16
22/22 23/8
verdict [1] 80/9
version [7] 27/12
27/19 28/7 28/17
28/24 29/13 51/10
very [38] 1/7 1/20 3/3
4/4 5/23 8/9 11/14
25/3 29/8 30/11 32/25
34/18 35/5 35/13
36/25 43/23 47/7
50/15 53/3 53/17
53/17 60/13 63/1
71/11 71/13 74/14
74/24 78/5 86/3 91/3
93/17 101/25 105/12
106/21 107/8 107/8
107/15 107/16
vestige [1] 85/21
victim [1] 60/24
view [13] 11/19 17/6
17/8 35/20 45/5 46/13
51/15 52/18 57/9
71/11 73/17 81/15
84/3
viewpoint [1] 39/22
views [1] 47/11
visibility [1] 25/25
visible [1] 80/4
voiced [1] 76/10
volume [1] 23/4
voluntarily [1] 5/2
volunteer [1] 99/20
volunteered [1]
101/11
WwW
wait [1] 37/13
waiting [1] 37/10
walk [1] 73/2
want [30] 1/23 3/24
5/1 5/9 6/19 8/20
15/11 20/11 24/23
26/10 34/15 37/25
43/11 44/4 44/21 48/8
53/3 53/10 54/3 56/22,
58/22 59/2 59/12 67/1
71/7 74/12 77/7 78/14
86/3 95/2
wanted [15] 26/5
26/10 34/10 45/18
56/12 56/13 73/7 84/8
97/3 99/3 99/4 100/2
103/3 103/13 104/9
wanting [4] 5/3 20/22
44/20 48/9
wants [1] 20/11
Warmington [5]
64/21 67/6 67/12
67/25 68/6
Warmington's [2]
67/20 67/22
warn [1] 67/23
warned [3] 67/5
67/11 68/15
was [317]
wasn't [18] 17/6
29/11 31/17 52/20
54/5 54/20 62/6 62/11
69/2 69/3 69/5 70/18
70/22 81/20 84/12
86/2 104/4 104/22
watching [1] 35/18
way [25] 4/7 14/10
17/6 21/3 24/2 25/4
25/6 26/11 32/7 33/6
36/17 37/23 48/17
49/15 51/7 54/13
54/19 54/20 73/24
75/6 75/12 81/18
83/17 86/23 105/3
WBD [2] 44/10 44/13
WBON0000528 [1]
19/2
WBON0000746 [2]
77/8 97/10
WBON0000834 [1]
95/3
we [200]
we'd [1] 105/15
we'll [13] 33/15 34/21
34/23 34/24 37/13
54/21 58/6 62/18
74/22 84/16 86/8
107/12 107/13
we're [8] 10/14 10/24
35/3 36/18 37/10
43/18 91/10 91/12
we've [10] 6/14 31/4
45/13 46/2 46/21
51/19 55/19 55/24
64/13 83/21
week [2] 81/24 81/24
weekly [1] 31/7
well [47] 11/12 20/1
32/17 33/5 33/11
33/22 34/21 35/2 35/3
37/7 40/19 41/9 42/7
45/13 46/19 47/15
47/18 51/17 52/5
54/21 55/21 56/15
56/16 56/20 56/22
60/20 66/7 67/23 71/7I
72/10 74/15 75/14
76/17 77/7 77/24
81/10 83/16 83/24
84/15 84/17 90/22
91/9 98/16 102/5
102/16 104/21 107/8
went [9] 16/23 27/7
44/10 45/19 47/12
48/21 55/20 62/8
77123
were [139]
weren't [7] 39/19
42/23 47/3 53/15
60/12 70/7 105/9
what [89] 1/16 3/20
5/10 6/3 8/12 10/14
10/14 12/3 16/21 17/1
20/11 20/19 23/16
23/16 25/21 25/25
27/4 29/25 31/24 32/9I
34/19 36/6 36/11 39/6
40/7 41/23 42/5 42/10
42/12 42/21 45/14
45/15 45/17 46/7 46/7)
46/24 48/4 48/13 49/7
50/13 50/16 53/5 53/9I
54/7 55/20 57/21
57/21 58/14 59/9
59/16 61/13 63/12
64/5 64/6 65/12 68/4
68/10 69/17 69/24
73/5 73/14 74/3 74/9
74/10 76/1 76/19
77/11 78/10 81/5 81/8)
81/18 81/21 83/13
84/13 84/13 85/20
87/20 91/17 94/6 95/4I
96/3 97/22 99/13
99/14 99/20 101/7
102/4 102/19 106/14
Whatever [1] 59/25
whatsoever [1] 48/10)
when [20] 1/12 25/14
38/25 40/13 42/7 51/8)
52/19 58/7 59/7 61/7
61/25 62/7 62/8 71/24
74/11 74/15 75/3
99/11 99/17 107/13
whenever [2] 106/10
106/12
(46) turning - whenever
Ww
where [22] 4/3 9/23
10/6 10/15 10/19 12/9)
18/11 23/14 39/19
46/12 46/25 48/23
55/20 57/24 58/9
63/25 66/3 67/5 72/8
73/21 79/22 93/15
whereas [2] 60/4
60/19
whereby [1] 105/5
whether [24] 5/19
9/18 12/20 20/6 35/24
46/11 57/17 61/12
62/9 68/3 69/15 70/8
70/19 81/5 87/11
89/21 92/9 93/10
97/17 100/6 100/21
101/12 101/20 101/21
which [82] 2/11 2/11
4/4 6/13 8/12 9/3 9/9
10/1 10/9 19/22 22/17)
24/8 24/19 26/5 28/14
28/19 29/13 30/18
31/9 31/11 36/4 36/25
37/6 37/11 39/11
39/17 39/24 41/25
43/7 44/4 47/1 50/7
50/8 51/8 52/13 52/14
58/2 58/12 58/23 59/9
59/20 60/14 62/4 66/2
68/12 68/19 69/11
69/25 71/14 76/20
76/20 77/3 78/13 79/4
79/6 79/14 79/24 81/3
82/9 82/15 83/15
83/18 86/6 87/6 88/6
88/12 89/4 89/23
89/25 90/22 91/4 91/7
91/22 92/22 93/21
95/3 97/16 99/3 101/4
102/21 103/15 105/18}
while [4] 19/6 37/10
45/3 105/7
whilst [3] 16/2 82/19
107/2
whitewash [1] 60/19
who [31] 12/19 12/21
12/25 18/22 20/15
26/3 35/15 43/22
44/13 46/3 47/5 49/6
54/16 54/22 55/5
56/15 60/6 60/9 60/23,
61/1 61/15 64/21
65/21 65/23 67/19
75/16 80/18 81/7
84/12 88/23 88/23
whole [6] 14/19
17/10 51/22 73/23
89/21 96/8
whose [3] 12/12
26/23 26/24
why [17] 14/9 31/16
43/3 43/4 46/16 51/14
51/17 52/5 52/7 54/8
61/20 67/23 68/14
68/14 70/8 84/3 105/9)
wide [3] 61/11 61/19
64/2
widely [3] 93/8 94/10
94/15
wider [1] 102/15
will [40] 3/24 4/6 5/3
5/21 7/16 7/20 8/3
11/1 11/2 11/17 12/9
12/16 12/19 12/20
13/25 15/7 15/7 21/24
22/17 24/14 33/20
33/24 34/8 47/10 50/3
50/8 54/11 59/16
59/17 59/19 59/25
60/1 60/4 60/5 60/7
67/14 67/18 68/17
72/13 97/10
Williams [13] 16/13
17/3 18/8 23/24 26/8
31/7 55/4 64/14 71/8
77/9 86/5 87/22 88/2
willing [2] 24/15
48/24
Wilson [1] 99/7
winning [1] 12/13
wish [5] 2/19 6/2
12/21 19/19 22/3
within [8] 6/13 28/12
32/12 32/15 39/10
49/13 63/14 92/22
without [7] 8/4 12/14
18/13 39/14 44/20
103/4 106/2
WITN00050100 [1]
48/4
WITN10390201 [1]
112
witness [51] 1/13 2/4
2/7 2/18 2/20 2/25 3/5
3/5 3/7 3/9 3/11 3/14
3/15 3/17 4/2 4/7 5/16
6/2 6/8 8/16 8/17
10/24 16/6 23/21
23/22 44/7 48/2 48/25
58/2 58/13 66/17 77/2
77/4 80/21 82/1 82/24
82/24 87/14 89/5
89/15 92/15 95/11
95/23 103/2 103/8
104/23 105/10 105/23)
106/6 106/21 107/9
witnesses [6] 1/24
2/5 3/18 6/5 15/7
106/10
Womble [8] 2/12 2/22
3/2 3/6 9/25 21/25
22/4 64/22
won't [2] 76/18 98/16
wonder [2] 55/20
101/12
woodwork [1] 57/5
word [2] 28/15 28/18
words [8] 20/20 36/2
65/9 77/19 86/20 93/2
94/10 95/23
work [12] 2/6 5/19
45/16 52/24 56/21
68/12 69/19 71/20
72/13 78/2 97/13
99/12
worked [4] 2/15
36/20 51/25 52/19
working [3] 51/9
62/14 66/21
worried [1] 19/18
worst [1] 69/4
would [98] 3/7 5/6
5/8 5/17 6/13 7/12 8/9
8/11 8/13 8/25 9/1 9/4
10/3 10/14 11/24
11/24 11/25 12/4
12/15 17/3 21/3 21/5
23/14 24/7 27/2 27/3
28/3 28/14 30/20 33/3
33/8 34/7 34/16 34/20
37/3 37/5 37/6 38/18
40/7 40/9 40/18 40/22
41/25 42/9 42/9 43/23
44/11 46/16 55/7
55/13 55/25 56/1 56/2
56/6 56/12 56/13 58/1
59/18 61/10 61/13
61/18 63/20 63/21
64/25 72/7 73/13
73/19 73/21 73/23
74/6 76/21 76/23 77/3
78/11 80/15 80/16
81/14 83/10 88/4
89/18 89/25 90/1 90/6
90/7 90/11 90/12
90/13 90/17 90/23
91/1 91/8 97/9 98/23
101/9 101/13 102/8
102/11 105/18
would-be [1] 33/3
wouldn't [14] 15/15
55/14 56/14 57/15
58/3 73/23 76/22 90/9
91/9 102/12 105/14
write [3] 30/20 67/10
92/20
writer [2] 34/19 74/13}
writing [8] 24/20
24/24 55/10 56/1
72/23 83/18 89/6
92/10
written [7] 23/3 23/4
23/8 24/15 94/6 94/7
103/14
wrong [5] 62/6 62/6
64/10 76/21 97/23
wrote [1] 97/8
Y
yawning [1] 51/4
yeah [5] 20/2 26/7
40/12 40/12 94/24
year [4] 13/16 42/15
61/6 80/6
years [4] 2/10 11/24
19/2 43/21
yes [64] 1/6 3/13 13/1
32/3 32/14 33/4 33/11
34/3 34/4 35/9 35/13
44/18 44/25 50/20
53/17 54/11 54/24
58/19 58/22 59/23
60/17 61/20 62/22
64/8 65/25 66/11
66/25 67/1 67/7 75/12,
75/20 76/23 77/6
78/11 78/25 85/2
86/20 87/9 87/24
89/11 91/14 92/2
92/18 92/22 94/9
94/14 96/15 97/1
97/16 97/19 97/25
98/23 98/25 101/3
101/9 102/10 102/14
102/23 102/24 104/14
104/16 104/17 107/4
107/6
yesterday [23] 1/12
1/22 11/16 22/20 23/7I
35/17 35/21 35/23
36/3 36/10 41/9 41/12
49/4 52/10 62/17
63/10 65/15 69/24
70/14 70/17 71/5 89/2,
101/4
yet [5] 58/16 71/25
85/6 105/7 106/22
you [451]
you'd [2] 62/17 91/23
you'll [3] 74/16 92/19
97/6
you're [17] 10/11
14/15 16/8 21/15 25/8
40/4 45/3 58/5 59/3
65/22 69/22 79/17
81/8 85/20 86/22 90/4
106/22
you've [18] 8/16 8/19
10/23 23/9 23/20
33/12 44/24 49/3
55/23 55/23 56/24
76/17 76/24 80/20
81/22 83/12 90/4
97/19
your [72] 1/13 1/17
8/16 8/17 10/24 13/5
17/8 20/16 23/20 24/1
24/2 25/20 29/19
29/20 31/24 34/16
35/22 35/24 36/2
36/23 38/21 42/8
42/21 43/12 43/13
A4IT 44/8 45/1 45/2
46/17 48/25 49/2 49/7
49/17 49/19 50/6 50/7,
51/5 53/5 53/5 54/4
55/11 56/6 56/16
56/24 57/13 61/8 62/7I
62/11 63/14 71/24
71/24 75/18 79/8
80/21 81/18 86/3 86/5I
92/8 92/11 94/16
94/20 94/22 97/13
100/9 100/12 100/23
101/16 101/17 101/22)
103/2 107/8
(47) where - your